MONTALCINO TOWNHOUSE Privacy Policy (last updated 8/5/2019)

This Privacy Policy explains how we collect, use, process, and disclose your information across the MT Platform. The “MT Platform” refers to Montalcino Townhouse’s (“MT”) websites, our mobile, tablet and other smart applications, and all associated MT services.

When this policy mentions “MT,” “we,” “us,” or “our,” it refers to the La Palazzetta di Montalcino s.r.l. that is responsible for your information under this Privacy Policy (the “Data Controller”). The Data Controller is the Montalcino Townhouse entity that you are contracting with which, if you are booking or supplying Accommodation through the MT Platform, will be one of the following:

• If you are booking or supplying Accommodation located in, the Data Controller is La Palazzetta di Montalcino s.r.l.

Please see Section 10 for contact details of the companies listed above.

In this policy, we use a few terms which are defined as follows: A “Member” is anyone who has registered an MT account, including Guests. A “Guest” is someone who books, or seeks to book, MT Services. “Accommodation” means our Villa Palazzetta villa. “Payment Services” means any payment processing services provided through or in connection with a Member’s use of the MT Platform.

1. Information We Collect

There are three general categories of information that we collect.

1.1. Information You Give Us.

We collect information you share with us when you use the MT Platform in order to ensure the adequate performance of contracts between you and MT, or between you and a Supplier. The provision of this information is necessary to use the MT Platform and, without it, we will not be able to provide you with services that you request.

• Account Information. When you sign up for an MT account or submit a request for Accommodation booking information, we require certain information such as your name and email address.

• Profile Information. To use certain features within the MT Platform, we may need to ask you to complete a profile, which may include your address and phone number.

• Other Authentication-Related Information. To help create and maintain a trusted environment, and to the extent permitted by applicable laws, we may collect identification that you provide (like a photo of your government-issued ID) or other authentication information.

• Payment Information. When you use the Payment Services (such as when booking Accommodation or a travel-related experience through us or establishing a Supplier relationship via us), we require certain financial information (like your bank account or credit card information) to process payments and comply with applicable law. If you are a Supplier, we may require additional information such as your ID or tax ID (where permitted by applicable law), and other proof of identification or verification in order to verify your identity, provide the Payment Services to you, and comply with applicable law. If you are a Guest, we may retain your financial information to assist you with booking travel-related experiences with third parties.

• Communications with MT. When you communicate with MT, we collect information about your communication and any information you choose to provide.

• Other Information. You may otherwise choose to provide us information (such as your itinerary, food allergies, emergency contact information, travel preferences, and information about other guests accompanying you on your stay) when you fill in a form, speak to, or otherwise communicate with an MT representative, conduct a search, update or add information to your MT account, respond to surveys, participate in promotions, or use other features of the MT Platform.

1.2. Information We Automatically Collect from Your Use of the MT Platform.

When you use the MT Platform, we collect information about the services you use and how you use them, even if you don’t sign up for an MT account. We process this information for the activities and legal bases described in Section 2 below.

• Usage Information. We collect information about your interactions with the MT Platform, such as the pages or other content you view, your searches for villas, bookings you have made, the experiences and activities you book with others through us, and other actions on the MT Platform.

• Location Information. When you use certain features of the MT Platform, we may collect different types of information about your general location (e.g. IP address, zip code).

• Log Data. We automatically collect log information when you use the MT Platform, even if you have not created an MT account or logged in. That information includes, among other things: details about how you’ve used the MT Platform (including if you clicked on links to third party applications), IP address, access times, hardware and software information, device information, device event information (e.g., crashes, browser type), unique identifiers, and the page you’ve viewed or engaged with before or after using the MT Platform.

• Transaction Information. We collect information related to your transactions on the MT Platform or transactions made through the MT Platform, including the date and time, amounts charged, and other related transaction details.

• Cookies and Similar Technologies. We use cookies and other similar technologies, such as web beacons, pixels, and mobile identifiers. We may also allow our business partners to use these tracking technologies on the MT Platform, or engage others to track your behavior on our behalf. You may disable the usage of cookies through your browser settings. For more information on our use of these technologies, see our Cookie Policy.

• California Do Not Track Disclosure. We are committed to providing you with meaningful choices about the information collected on the MT Platform for third party purposes, which is why we provide in our Cookie Policy the Network Advertising Initiatives Consumer Opt-out link, Digital Advertising Alliances Consumer Opt-Out Link, and Google Analytics opt out link. However, we do not recognize or respond to browser-initiated Do Not Track signals.

1.3. Information We Collect from Third Parties.

We may collect information that others provide about you when they use the MT Platform, or obtain information from other sources and combine that with information we collect through the MT Platform. MT does not control, supervise or respond for how the third parties providing your information process your personal data, and any information request regarding the disclosure of your personal information to MT should be directed to such third parties.

• Third Party Services. If you link, connect, or login to your MT account with a third party service (e.g., Facebook, Twitter, Google), we may collect information from the third party service, such as your registration and profile information. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.

• Background Information. For certain Members in the United States, to the extent permitted by applicable laws, MT may obtain reports from public records of criminal convictions or sex offender registrations. For Members outside of the United States, to the extent permitted by applicable laws, MT may obtain the local version of background or registered sex offender checks. We may use your information, including your full name and date of birth, to obtain such reports. We will only collect this information where required by applicable laws or where necessary to ensure the adequate performance of our services for you.

• Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or fraud detection information, from third party service providers and/or partners (such as SafelyStay) and combine it with information we have about you. For example, we may receive background check results or fraud warnings from service providers like identity verification services for our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the MT Platform, including about your interactions from our partner ad networks. For example, if you book a restaurant reservation through MT, the restaurant may send information to us that you submitted to them, like your dining preferences or dining activity. We may receive information about you and your activities on and off the MT Platform through partnerships, or about your experiences and interactions from our partner ad networks.

2. How We Use The Information We Collect

We use, store, and process information about you to provide, understand, improve, and develop the MT Platform, and to create and maintain a trusted and safer environment.

2.1. Provide, Improve, and Develop the MT Platform.

• Enable you to access and use the MT Platform.

• Contact you about your booking requests, plan your stay at one of our villas, and make and manage your bookings.

• Enable you to communicate with other Members.

• Operate, provide, improve and optimize the MT Platform and experience, such as by performing analytics and conducting research.

• Personalize or otherwise customize your experience by, among other things making Accommodation suggestions, ranking search results or showing ads based on your search or booking history, and any preferences you provide to us, or that are signified by your search and booking history.

• Enable you to access and use the Payment Services, including collecting payment on behalf of a Supplier.

• Provide customer service.

• Send you service or support messages, such as updates, security alerts, and account notifications.

• If you provide us with your contacts’ information, we may use and store this information: (i) to facilitate your referral invitations, (ii) for fraud detection and prevention, and (iii) for any other purpose you authorize at the time of collection.

We process this information given our legitimate interest in improving the MT Platform and our users’ experience with it, and to ensure the adequate performance of our contract with you.

2.2. Create and Maintain a Trusted and Safer Environment.

• Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity.

• Conduct investigations and risk assessments.

• Verify or authenticate information or identification provided by you (such as to verify your Accommodation address or compare your identification photo to another photo you provide).

• Conduct checks against databases and other information sources.

• Comply with our legal obligations.

• Resolve any disputes with any of our users and enforce our agreements with third parties.

• Enforce our Terms of Service, Member agreements, and policies.

We process this information given our legitimate interest in protecting the MT Platform, to verify and ensure the adequate performance of our contract with you, and to comply with applicable laws.

2.3. Provide, Personalize, Measure, and Improve our Advertising and Marketing.

• Send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your communication preferences (including information about MT or partner campaigns and services, such as services offered by MT’s affiliate, Airbnb).

• Personalize, measure, and improve advertising.

• Administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by MT or its third party business partners.

• Carry out profiling on your characteristics and preferences (based on the information you provide to us, your interactions with our services, and your search and booking history) to send you promotional messages, marketing, advertising and other information that we think may be of interest to you.

We process this information given our legitimate interest in protecting the MT Platform, to measure the adequate performance of our contract with you, and to comply with applicable laws.

3. Sharing & Disclosure

3.1. With Your Consent or Where Authorized by Law.

• We may share your information at your direction or as described by us to you at the time of sharing, such as if you, as a Guest, have requested us to connect you with a third party vendor or to purchase services from a third party vendor on your behalf, in connection with your booking (e.g., an insurance provider or activities provider), or if you, as a Supplier, have agreed to let us market your Accommodation through, or refer you to, a third party’s platform. In these situations, you are authorizing MT to disclose to these third party vendors information required to book them and to receive the relevant services from them. This could include special preferences or requests, and any additional guest information. These third party vendors are not controlled by MT and personal information shared with them is subject to their privacy policies and practices.

• We may also share certain contact details about you, such as your name, email and past reservations in MT, to other companies and business partners of MT, including our affiliate, Airbnb, who may then send you marketing communications about products or services that may interest you.

3.2. Sharing between Suppliers and Guests.

• When you as a Guest submit a booking request, certain information about you may be shared with the Supplier to coordinate the booking, such as your name, contact details, and arrival date.

• When you as a Supplier have a confirmed booking, certain of information about you may be shared with the Guest to coordinate the booking, such as your full name, phone number, and Accommodation address.

Sharing this information is necessary to provide Guests with our services, and we don’t share your billing and payout information with other Members.

3.3. Reviews, Listings, and other Public Information.

The MT Platform publishes information that is visible to the general public. For example:

• Public Listing pages are publicly visible and include information such as the Accommodation’s approximate or exact location, Listing description, calendar availability, and any additional information the Supplier chooses to share.

• After completing a booking, Guests may write reviews which may appear publicly on Listing pages (and other pages on which we may market Accommodations) under their first name, last initial, and general location.

• If you submit content on our blog, in a public forum, or in a social media post, or use a similar feature on the MT Platform, that content is publicly visible.

Information you share publicly on the MT Platform may be indexed through third party search engines. If you change your settings or your public-facing content, these search engines may not update their databases. We do not control the practices of third party search engines, and they may use caches containing your outdated information.

3.4. Service Providers.

We use a variety of third party service providers to help us provide services related to the MT Platform and ensure we can adequately provide you with our services. For example, service providers may help us: (i) verify or authenticate your identification, (ii) check information against public databases, (iii) assist us with background checks, fraud prevention, and risk assessment, or (iv) provide customer service, advertising, or payments services. These providers have limited access to your information to perform these tasks on our behalf, and are contractually obligated to use it consistent with this policy.

3.5. Additional Services by Suppliers.

Suppliers may use third party services available through the MT Platform to assist with managing their Accommodation or providing additional services, such as cleaning services, insurance or activities providers. Suppliers may use features on the MT Platform to share information about the Guest (like the Guest’s check-in and check-out dates, name, phone number, and anonymized email address) with that third party service provider for the purposes of coordinating the stay, managing the Accommodation, or delivering other services.

3.6. Safety and Compliance with Law.

MT may disclose your information to courts, law enforcement or governmental authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) to comply with legal process and to respond to claims asserted against MT, (ii) to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability, (iii) to enforce and administer our Terms of Use or other agreements with Members, (iv) for fraud investigation and prevention, risk assessment, customer support, product development and debugging purposes, or (v) to protect the rights, property or personal safety of MT, its employees, its Members, or members of the public.

We will attempt to notify Members about these 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 MT’s property, its Members and the MT Platform (collectively, “Risk Scenarios”). In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that Member 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.

3.7. Corporate Affiliates.

To help us provide the MT Platform, we may share your information within our corporate family of companies (both financial and non-financial entities) that are related by common ownership or control. Additionally, we share your information with our affiliates to support, integrate, promote, and improve the MT Platform and our affiliates’ services. Our affiliates include other La Palazzetta di Montalcino srl properties.

3.8. Widgets.

We may display parts of the MT Platform on sites operated by MT’s business partners, using technologies such as widgets or APIs.

3.9. Tax Authorities.

In jurisdictions where we facilitate the collection and remittance of occupancy taxes, Suppliers and Guests expressly grant us permission, without further notice, to disclose Suppliers’ and Guests’ data and other information relating to them or to their transactions, bookings, Accommodations and occupancy taxes to the relevant tax authority, including, but not limited to, the Supplier’s or Guest’s name, listing addresses, transaction dates and amounts, tax identification number(s), the amount of taxes received (or due) by Suppliers from Guests, and contact information.

3.10. Business Transfers.

If MT 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 personal 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.

3.11. Aggregated Data.

We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other de-identified information for industry and market analysis, regulatory compliance, demographic profiling, marketing and advertising, and other business purposes.

4. Other Important Information

4.1. Analyzing your Communications.

We may review, scan, or analyze your communications on the MT 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, we scan and analyze messages to mask contact information and references to other websites. In some cases, we may also scan, review, or analyze messages to debug, improve, and expand product offerings. We use automated methods where reasonably possible. However, occasionally we may need to manually review some 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 analyze your communications to send third party marketing messages to you, and we will not sell reviews or analyses of these communications.

These activities are carried out based on MT’s legitimate interest in ensuring compliance with applicable laws, preventing fraud, promoting safety, and improving and ensuring the adequate performance of our services.

4.2 Linking Third Party Accounts.

You may link your MT account with your account at a third party social networking service. When you create this link:

• 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 MT through this linkage is subject to any of your settings and authorizations on the MT Platform and the third party site.

We only collect your information from linked third party accounts to the extent necessary to ensure the adequate performance of our contract with you, or to ensure that we comply with applicable laws, or with your consent.

4.3 Google Maps/Earth.

Parts of the MT Platform use Google Maps/Earth services, including the Google Maps API(s). Use of Google Maps/Earth is subject to Google Maps/Earth Additional Terms of Use and the Google Privacy Policy.

5. Third Party Partners & Integrations

The MT Platform may contain links to third party websites or services, such as third party integrations, co-branded services, or third party-branded services (“Third Party Partners”). MT doesn’t own or control these Third Party Partners and when you interact with them, you may be providing information directly to the Third Party Partner. These Third Party Partners will have their own rules about the collection, use, and disclosure of information. We encourage you to review the privacy policies of the other websites you visit.

6. Your Choices

6.1. Managing Your Information.

You may access, update, and correct most of your basic personal information by logging into your MT account and reviewing your settings and profile. Where permitted by applicable law, you may request written copies of your personal information held by us. In some cases and where permitted by law, we may charge a fee which will be disclosed to you before we comply with your request. You are responsible for keeping your personal information up-to-date.

6.2 Data Retention & Account Cancellation.

We generally retain your information for as long as is needed to provide the MT Platform to you, or for as long as your account is active. If you no longer want us to use your information to provide the MT Platform to you, you may cancel your account or request us to erase your personal information. To cancel your MT account, contact us. If you cancel your account or request erasure of your personal information, note that:

• Information you have shared with others (such as Listing reviews) may continue to be publicly visible on the MT Platform in association with your first name, even after your MT account is cancelled.

• Some copies of your information (e.g. log records) may remain in our database, but are disassociated from personal identifiers.

• Because we maintain the MT Platform to protect from accidental or malicious loss and destruction, residual copies of your information may not be removed from our backup systems for a limited period of time.

• MT may retain certain information to the extent necessary to comply with its legal obligations.

• MT may retain certain information as necessary for its legitimate business interests, such as fraud detection and prevention, enhancing user safety, and defending itself against legal claims. For example, if MT removes a user account for fraud or user safety reasons, MT may retain certain information from that account to prevent that user from opening a new MT account in the future.

6.3 Withdrawing Consent.

In some jurisdictions, applicable law may entitle you to withdraw consent you previously gave to MT to process your information and to end your use of the MT Platform by cancelling your account as described in this section. Additionally, you may have the right to limit the ways in which we use your personal information.

For information about, and to opt-out of, online behavioral advertising, please see our Cookie Policy.

6.4 Data Portability.

In some jurisdictions, applicable law may entitle you to request a copy of your personal information that you have provided to us and/or to request us to move such personal information to another service provider. 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 format.

6.5 Restricting Processing.

In certain extraordinary circumstances (e.g. where you think that MT is not holding accurate data about you) and in line with applicable law, you may request MT to temporarily restrict our use of your personal information for a limited period of time until the extraordinary circumstance that justified the restriction ends.

6.6 Objecting to Processing (including Automated Decision-Making).

In some jurisdictions, applicable law may entitle you to require MT not to process your personal information for certain specific purposes, such as profiling or marketing purposes.

6.7 Exercising Rights and Lodging Complaints.

If you would like to learn more about, or exercise any of, the rights described in this Section 6, contact us at info@lapalazzettadimontalcino.it. We may ask you to verify your identity before taking further action on your request. You have the right to lodge complaints about the data processing activities carried out by MT before competent data protection authorities.

7. Operating Globally

As described in this Privacy Policy, we may sometimes share your information within our family of companies or with third parties.

7.1 Service Providers.

Where we engage third party service providers to help us provide services related to the MT Platform, we may need to transfer them your personal information for the purposes described in this Privacy Policy. These services providers may be located inside or outside of the European Economic Area (“EEA”), including in countries that are considered to provide a level of data protection equivalent to that provided in the EEA (like Canada) and other countries that do not, including the United States and Barbados. When transferring your personal information to service providers in these countries, we will ensure that such information is processed there in a manner consistent with this Privacy Policy.

When you use the MT Platform, you authorize us to transfer, store, and process your information in such countries. Laws in these countries may differ from the laws applicable to the place where you live. By using the MT Platform, you consent to transferring your data to these countries.

7.2 California Residents.

California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year. MT does not share personal information with third parties for their own direct marketing purposes without your prior consent. Accordingly, you can prevent disclosure of your personal information to third parties for their direct marketing purposes by withholding consent. If you do opt-in to receiving marketing and other communications from a third party, please be advised that the information you elect to share with that third party will be governed by the third party’s privacy policy and terms of service, and we encourage you to review those policies before providing consent for MT to share your information.

8. Security

We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration.

9. Changes to this Privacy Policy

MT reserves the right to modify this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on the MT Platform and update the “Last Updated” date at the top of this Privacy Policy. We will also provide you with notice of the modification by email at least thirty (30) days before the date they become effective. If you disagree with the revised Privacy Policy, you may cancel your Account. If you do not cancel your MT account before the date the revised Privacy Policy becomes effective, your continued access or use of the MT Platform will constitute acceptance of the revised Privacy Policy.

10. Contact

If you have any questions or complaints about this Privacy Policy or MT’s information handling practices (including how our service providers process your personal information), you may contact MT at: Data Collection Officer (MT), PO Box 1765, Jackson, WY, USA 83001. You may also email us at info@lapalazzettadimontalcino.it.