Privacy Policy

Data collection

The personal data Birdsong Home collects in regards to Guests depends on the context of the business relationship and their interaction with Birdsong Home, the choices made by the Guest and the products, services, and features they use.

Please note that the data items in the sections below are only considered “personal data” when concerning a natural person (meaning an individual human being). These data items are not considered “personal data” when concerning a legal person or entity.

The personal data Birdsong Home collects about our Guests can include the following:

Personal data you give to us

  • Contact details
    We collect contact data from our Guests, such as first and last name, date of birth (as required), addresses, business email addresses, telephone, and fax numbers.
  • Financial data
    We collect data necessary for payment and invoicing purposes (including your bank details, bank account number, and VAT number) and data otherwise necessary for the processing of credit slips.
  • Verification details
    Birdsong Home can ask (representatives of) Guests to provide a copy of company registration documents, their ID card or passport, a photo, a video, or other relevant information to verify the authenticity of the Guest. This may also include proof-of-licenses or tax information.
  • Other data
    When a Guest communicates with Birdsong Home, we collect and process information about these communications. During calls with our support center, live listening may be conducted and calls may be recorded for quality control and training purposes. These recordings may also be used for the handling of claims and fraud detection purposes.
    Recordings are kept for a limited amount of time before being automatically deleted, unless Birdsong Home has a legitimate interest to keep the recording for longer. This only happens in exceptional cases, such as for fraud investigation, compliance, and legal purposes.

Information we collect automatically

Depending on the business relationship, Birdsong Home may also collect information automatically—some of which may be personal data. This data is collected when a Guest uses online services such as a registration form, a user account (e.g., for the Extranet or partner center), a vendor management platform, or a Birdsong Home app, like Pulse.

The data collected may include:

  • Language settings,
  • IP address,
  • Location,
  • Device settings,
  • Device operating system,
  • Log information,
  • Time of usage,
  • URL requested,
  • Status report,
  • User agent (information about the browser version),
  • Result (viewer or booker),
  • Browsing history,
  • User Booking ID,
  • And the type of data viewed.

Personal data you give to us about others

By sharing other individuals’ personal data for business purposes—such as data belonging to your staff members—you confirm that these individuals have been informed about the use of their personal data by Birdsong Home in accordance with this privacy statement. You also confirm that you have obtained all necessary consent, as required by the laws and regulations applicable to you.

Other information we receive from other sources

  • Information on insolvencies
    In insolvency matters, Birdsong Home can receive information relating to Guests from insolvency administrators, courts, or other public authorities.
  • Data related to law enforcement and tax authority requests
    Law enforcement or tax authorities can contact Birdsong Home with additional information about Guests in the event that they are affected by an investigation.
  • Fraud detection and prevention, risk management, and compliance
    In certain instances, and as permitted by applicable law, Birdsong Home may need to collect data through third-party sources for fraud detection and prevention, risk management, and compliance purposes.

Processing purposes

Birdsong Home uses the previously described Guest information, some of which may be personal data, as relevant, for the following purposes:

A. Registration and administration

Birdsong Home uses account details, contact details, and financial data to manage the business relationship with the Guest. This includes for registration and verification purposes.

Certain information, including a Guest’s name and address, can be used for other purposes in accordance with the agreement entered into between the Guest and Birdsong Home.

B. Customer service

Birdsong Home uses the information provided by Guests (which may include personal data) to provide support services—for example, to respond to requests, questions, or concerns from Guests or customers.

C. Other activities, including marketing

As relevant to the business relationship, Birdsong Home uses personal data for communications, including providing information about system or product updates, sending the Birdsong Home newsletter, inviting Guests to participate in referral programs or competitions or for other marketing communications. When we use personal data to send direct marketing messages electronically, we will offer appropriate opt-out options.

D. Messaging tools

Guests can contact Birdsong Home to forward reservation information or questions. Birdsong Home may use automated systems to review, scan, and analyze communications for the following purposes:

  • Security,
  • Fraud prevention,
  • Compliance with legal and regulatory requirements,
  • Investigations of potential misconduct,
  • Product development and improvement,
  • Research,
  • Customer engagement (including to provide guests with information or offers we believe may be of interest to them),
  • And customer or technical support.

Communications sent or received using Birdsong Home communication tools will be received and stored by Birdsong Home.

E. Analytics, improvement, and research:

Birdsong Home uses information provided to us, which may include personal data, for analytical purposes. This is part of our drive to improve Birdsong Home products and services and enhance user experience.

This data can also be used for testing purposes, troubleshooting, and to improve the functionality and quality of Birdsong Home’s online services. We also invite Guests to participate in surveys and conduct other market research from time to time.

Certain Guests may be invited to join a dedicated online platform to interact with Birdsong Home and/or exchange experiences with other Guests.

Please consult the information Birdsong Home provides when you are invited to participate in a survey, market research or to join an online platform, to understand how your personal data may be treated differently than described in this Privacy Statement.

F. Security, fraud detection, and prevention

We process the information provided to us, which may include personal data, in order to investigate, prevent, and detect fraud and other illegal acts. This may be personal data a Guest has provided to Birdsong Home, for example, for verification purposes as part of the registration process, personal data collected automatically, or personal data obtained from third-party sources (including from guests).

Birdsong Home may also use personal data to facilitate investigation and enforcement by competent authorities, where necessary. For these purposes, personal data may be shared with law enforcement authorities.

Birdsong Home can also use personal data for risk assessment and security purposes, including the authentication of users.

G. Legal and compliance

In certain cases, Birdsong Home needs to use the information provided (which may include personal data) to handle and resolve legal disputes or for regulatory investigations, risk management, and compliance. We may also use it to enforce our agreement(s) with Guests or solve a complaint or claim involving a guest, as reasonably expected, and in accordance with internal policies and procedures.

In addition, we may need to share information about Guests (including personal data) where required by law or strictly necessary to respond to requests from competent authorities. This includes tax authorities, courts, other governmental, and public authorities or local municipalities (e.g., in relation to short-term rental laws).

If we use automated means to process personal data, which produces legal effects or significantly affects you or other natural persons, we will implement suitable measures to safeguard yours or the other person’s rights and freedoms. This includes the right to obtain human intervention.

Legal bases

As applicable for purposes A and B, Birdsong Home relies on the legal basis that the processing of the personal data is necessary for the performance of the agreement between the Guest and Birdsong Home. If the required information is not provided, Birdsong Home cannot work with a Guest, nor can we provide customer service.

In view of purposes C to G, Birdsong Home relies on its legitimate interest to provide its services or obtain services from Guests, to prevent fraud and to improve its services. When using personal data to serve Birdsong Home’s or a third party’s legitimate interest, we will always balance the impacted individual’s rights and the protection of their information against Birdsong Home’s and/or the third party’s rights and interests.

For purposes F and G, Birdsong Home also relies, where applicable, on compliance with legal obligations (such as lawful law-enforcement requests). Finally, where needed under applicable law, Birdsong Home will obtain your consent prior to processing personal data, including for marketing purposes or as otherwise required by law.

If you wish to object to the processing set out under C to E and are unable to find a way to opt out directly (for example, in your account settings), please contact us

Data sharing

  • Sharing with affiliates
    In order to support the use of the Birdsong Home services, your information (which may include personal data) may be shared with members of the Birdsong Home group. To find out everything you need to know about the Birdsong Home, visit our About Us page.
  • Sharing with third parties
    We share Guests’ information (which may include personal data) with third parties, as permitted by law and as described below:
    • Service providers (incl. suppliers). We share personal data with selected third-party service providers to provide our products and services, prevent and detect fraud, store data, and otherwise support our business processes, or so they can conduct business on our behalf.
    • Payment Providers and other financial institutions. To process payments between a Guest and Birdsong Home, relevant personal data is shared with payment providers and other financial institutions.
    • Sanction list screening or risk management as required by applicable law.
    • Compelled disclosure. When legally required, strictly necessary for the performance of our services, in legal proceedings, or to protect our rights, we disclose personal data to law enforcement authorities, investigative organizations, or other group members.
  • Sharing and disclosure of aggregated data
    We may share information with third parties in an aggregate form and/or another form that does not allow the recipient to identify you, for example, for industry analysis or demographic profiling.

Security

We have procedures in place to prevent unauthorized access to and misuse of personal data.

We use appropriate business systems and procedures to protect and safeguard information, including personal data. We also use security procedures and technical and physical restrictions for accessing and using the personal data on our servers. Only authorized personnel are permitted to access personal data in the course of their work.

Data retention

We will retain personal data for as long as deemed necessary to manage the business relationship with a Guest, to provide Birdsong Home services to a Guest and to comply with applicable laws (including those regarding document retention), resolve disputes or claims with any parties, and as otherwise necessary to allow us to conduct our business.

All personal data we retain about you as a Guest is subject to this Privacy Statement and our internal retention guidelines. If you have questions about the specific retention periods for the various types of personal data we process, please get in touch. 

Your choices and rights

Depending on where you are located or the Birdsong Home entity processing your personal data, different rights may apply to the processing of that data, as set out in this privacy statement. As applicable:

  • You can ask us for a copy of the personal data we hold about you,
  • You can inform us of any changes to your personal data, or you can ask us to correct any of the personal data we hold about you,
  • In certain situations, you can ask us to erase, block, or restrict the personal data we hold about you, or object to particular ways in which we are using your personal data,
  • In certain situations, you can also ask us to send the personal data you have given us to a third party.

Where we are using your personal data on the basis of your consent, you are entitled to withdraw that consent at any time, subject to applicable law. Where we process your personal data based on legitimate interest or public interest, you also have the right to object at any time, subject to applicable law.

Contact us

If you have questions, requests, or concerns about how we process your personal data, or would like to exercise any of the rights you have under this Privacy Statement, contact us. You can also contact your local data protection authority.

We address privacy specific questions, requests, and concerns that are reported to us using internal policies and procedures based on applicable privacy laws, regulations, and guidance. We revisit and enhance these policies and procedures regularly, also taking into account Guest feedback.

Changes to this Privacy Statement

Just as our business is always changing, this Privacy Statement also changes from time to time. If we plan to make material changes or changes that have an impact on you, we will always contact you in advance. An example of this kind of change would be if we were to start processing your personal data for purposes that aren’t detailed above.

 

April 28, 2022