Last updated: July 17, 2023
ROMIO exists to help build connections between people and make the world more open and inclusive. In short—to build a world where anyone can belong anywhere. We are a community built on trust. A fundamental part of earning that trust means being clear about how we use your information and protecting your human right to privacy.
IMPORTANT SUPPLEMENTAL INFORMATION
Outside of the United States. If you reside outside of the United States, such as in the European Economic Area ("EEA") visit our Outside of US page to learn about (i) the controller(s) of your personal information, (ii) legal bases, including legitimate interests, for collecting and processing your personal information, (iii) safeguards relied upon for transferring personal information outside the EEA, (iv) your rights, and (v) contact details of the controller(s) and Data Protection Officer.
2. PERSONAL INFORMATION WE COLLECT
2.1 Information Needed to Use the ROMIO Platform.
We collect personal information about you when you use the ROMIO Platform. Without it, we may not be able to provide all services requested. This information includes:
- Contact, Account, and Profile Information. Such as your first name, last name, phone number, postal address, email address, date of birth, and profile photo, some of which will depend on the features you use.
- Identity Verification and Payment Information. Such as images of your government-issued ID (as permitted by applicable laws), your ID number or other verification information, a selfie when we verify your ID, bank account or payment account information. If you are not an ROMIO user, we may receive payment information relating to you, such as when an ROMIO user provides your payment card to complete a booking. If a copy of your ID is provided to us, we may scan, use, and store information contained in your ID to verify your identity and for security purposes.
2.2 Information You Choose to Give Us.
You can choose to provide us with additional personal information. This information may include:
- Additional Profile Information. Such as gender, preferred language(s), city, and personal description. Some of this information as indicated in your account settings is part of your public profile page and will be publicly visible.
- Address Book Contact Information.
- Other Information. Such as when you fill in a form, add information to your account, respond to surveys, post to community forums, participate in promotions, communicate with ROMIO Support and other Members, import or manually enter address book contacts, provide your address and/or geolocation, or share your experience with us. This may include health information if you choose to share it with us.
2.3 Information Automatically Collected by Using the ROMIO Platform and Our Payment Services.
When you use the ROMIO Platform and Payment Services, we automatically collect personal and other information. This information may include:
- Geolocation Information. Such as precise or approximate location determined from your IP address, mobile or other device’s GPS, or other information you share with us, depending on your device settings. We may also collect this information when you’re not using the app if you enable this through your settings or device permissions.
- Usage Information. Such as the pages or content you view, searches for Listings, bookings you have made, additional services you have added, and other actions on the ROMIO Platform.
- Log Data and Device Information. Such as details about how you've used the ROMIO Platform (including if you clicked on links to third-party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, and the pages you’ve viewed or engaged with before or after using the ROMIO Platform. We may collect this information even if you haven’t created an ROMIO account or logged in.
- Payment Transaction Information. Such as payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, PayPal email address, IBAN information, your address, and other related transaction details.
2.4 Personal Information We Collect from Third Parties.
We collect personal information from other sources, such as:
- Third-Party Services. If you link, connect, or login to the ROMIO Platform with a third-party service (e.g., Google, Facebook, WeChat), you direct the service to send us information such as your registration, friends list, and profile information as controlled by that service or as authorized by you via your privacy settings at that service.
- Background Information. For Members in the United States, to the extent permitted by applicable laws, we may obtain, for example, reports of criminal records, sex offender registrations, and other information about you and/or your background. For Hosts in India, to the extent permitted by applicable laws, we may perform criminal background checks. For Members outside of the United States, to the extent permitted by applicable laws and with your consent where required, we may obtain police, background, or registered sex offender checks. We may use your information, including your full name and date of birth, to obtain such reports.
- Enterprise Product Invitations and Account Management. Organizations that use our Enterprise products may submit personal information to facilitate account management and invitations to use enterprise products.
- Referrals and Co-Travelers. If you are invited to the ROMIO Platform, for example, as a co-traveler on a trip, the person who invited you can submit personal information about you such as your email address or other contact information.
- Other Sources. To the extent permitted by applicable law, we may receive additional information about you, demographic data, or information to help detect fraud and safety issues from third-party service providers and/or partners, and combine it with information we have about you. For example, we may receive background check results or fraud warnings from identity verification service providers for use in our fraud prevention, security investigation, and risk assessment efforts. We may receive information about you and your activities on and off the ROMIO Platform, or about your experiences and interactions from our partners. We may receive health information, including but not limited to, health information related to contagious diseases.
3. HOW WE USE INFORMATION WE COLLECT
3.1 Provide, Improve, and Develop the ROMIO Platform.
We may process this information to:
- enable you to access the ROMIO Platform and make and receive payments,
- enable you to communicate with other Members,
- process your request,
- perform analytics, debug, and conduct research,
- provide customer service training,
- send you messages, updates, security alerts, and account notifications,
- process, handle, or assess insurance claims or similar claims,
- personalize and customize your experience based on your interactions with the ROMIO Platform, your search and booking history, your profile information and preferences, and other content you submit, and
- enable your use of our enterprise products and accommodation services.
If you provide us with your contacts’ information, such as your friends or co-travelers, we may process this information to: (i) facilitate your referral invitations, (ii) share your trip details and facilitate trip planning, (iii) detect and prevent fraud, and (iv) facilitate your requests or for any other purpose you authorize.
3.2 Create and Maintain a Trusted and Safer Environment.
We may process this information to:
- detect and prevent fraud, spam, abuse, security and safety incidents, and other harmful activities,
- conduct fraud prevention, security investigations, and risk assessments,
- verify or authenticate information provided by you,
- conduct checks against databases and other information sources, including background checks,
- comply with our legal obligations, protect the health and well-being of our Guests, Hosts, Hosts’ employees, and members of the public,
- resolve disputes with our Members, including sharing information with your co-Host(s) or additional Guests about disputes related to your role as a co-Host(s) or additional Guests,
- enforce our agreements with third parties,
- determine eligibility for certain types of bookings, such as Instant Book,
- comply with law, respond to legal requests, prevent harm, and protect our rights (see section 4.5),
- enforce our Terms and other policies
- assess or evaluate your interactions with the ROMIO Platform and information obtained from third parties. In limited cases, automated processes, which analyze your account and activities on the ROMIO platform as well as information in relation to activities on and off the ROMIO platform that can be associated with you, could restrict or suspend your access to the ROMIO Platform if such processes detect activity that may pose a safety or other risk to romio, our community, or third parties. If you would like to challenge decisions based on automated processes, please contact us via the Contact Information section below. You can find out more about how our system determines whether certain reservations may carry a higher risk for incidentshere.
3.3 Provide, Personalize, Measure, and Improve our Advertising and Marketing.
We may process this information to:
- send you promotional messages, marketing, advertising, and other information based on your preferences and social media advertising through social media platforms,
- personalize, measure, and improve our advertising,
- administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by ROMIO or its third-party partners,
- analyze characteristics and preferences to send you promotional messages, marketing, advertising, and other information that we think might be of interest to you,
- invite you to events and relevant opportunities, and
- send, with your consent, promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences.
3.4 Analyzing and Sharing Your Communications.
We may review, scan, or analyze your communications on the ROMIO Platform for reasons outlined in the "How We Use Information We Collect" section of this policy, including fraud prevention, security investigations, risk assessment, regulatory compliance, product development, research, analytics, enforcing our TOS 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 sites, and subject to applicable law, we scan and analyze all images uploaded by users to the ROMIO platform in message threads, profiles, listings, and experiences for certain illegal or inappropriate activities (such as evidence of child exploitation) for the purpose of identifying and reporting content violations to appropriate authorities. 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. Occasionally we may need to manually review communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools. We will not review, scan, or analyze your messaging communications to send third-party marketing messages to you and we will not sell reviews or analyses of these communications. We may also share your communications as set out in the "Sharing & Disclosure" section.
3.5 Linking Third-Party Accounts.
You can link your ROMIO account with certain third-party services like social networks. Your contacts on these third-party services are referred to as "Friends." When you direct the data sharing by creating this link:
- some of the information provided to us from linking accounts may be published on your public profile,
- your activities on the ROMIO Platform may be displayed to your Friends on the ROMIO Platform and/or that third-party service,
- a link to your public profile on that third-party service may be included in your ROMIO public profile,
- other ROMIO users may be able to see any Friends that you may have in common with them, or that you are a Friend of their Friend if applicable,
- other ROMIO users may be able to see any schools, hometowns, or other groups you have in common with them as listed on your linked social networking service,
- information you provide to us from the linking of your accounts may be stored, processed, and transmitted for fraud prevention, security investigations, and risk assessment purposes, and
- publication and display of information that you provide to the ROMIO Platform through this linkage is subject to your settings and authorizations on the ROMIO Platform and the third-party service.
3.6 Provide Payment Services. Personal information is used to enable or authorize third parties to use Payment Services, such as to:
- detect and prevent money laundering, fraud, abuse, and security incidents, as well as conduct risk assessments,
- comply with legal and compliance obligations (such as anti-money laundering regulations and sanctions enforcement),
- enforce the Payment Terms and other payment policies, and
- provide and improve Payment Services.
4. SHARING & DISCLOSURE
4.1 Sharing With Your Consent or at Your Direction.
Where you provide consent, we share your information as described at the time of consent, such as when authorizing a third-party application or website to access your ROMIO account or participating in promotional activities by ROMIO partners or third parties.
Where permissible under applicable law, we may use certain information about you, such as your email address, that we share with social media platforms after de-identifying it to generate leads, drive traffic to romio, or otherwise promote our products and services.
4.2 Sharing Between Members.
To help facilitate bookings or other interactions between Members (who may be located in, or use service providers located in, jurisdictions with varying levels of data protection), we may share information in situations such as:
- Between Guest(s) and Host(s) when:
- A booking request is made, when there is a co-host, or a dispute is submitted, such as profile, name, names of any additional Guests, cancellation history, review information, age of guest (unless prohibited by applicable law), dispute outcome (when applicable), and other information you choose to share and submit.
- A booking is confirmed, additional information is shared to assist with coordinating the trip, such as profile photo and phone number.
- You as a Host have a confirmed booking, certain information is shared with the Guest (and any additional Guests they invite, if applicable) to coordinate the booking, such as your profile, full name, phone number, and Listing address.
- You communicate with a Member, such as your name, profile picture, and message content.
- Between Guests when:
- You as a Guest invite additional Guests to a booking, certain information is shared with each additional Guest, such as your name, travel dates, Host name, Listing details, Accommodation address, and other related information.
- Between Hosts when:
- You accept an invitation to host with another Member, you authorize those other Member(s), such as co-Hosts, to access and update your information and Member Content, such as certain information like your full name, phone number, Listing address, calendar, Listing information, Listing photos, and email address.
4.3 Information You Publish in Profiles, Listings, and Other Public Information.
You can make certain information publicly visible to others, such as:
- Your public profile page, which includes your profile photo, first name (or initials where applicable), description, and city.
- Listing pages that include information such as the Accommodation or Experience’s approximate or precise location description, calendar availability, profile photo, aggregated demand information (like page views over a period of time), and additional information you choose to share.
- Reviews, ratings, and other public feedback.
- Content in a community or discussion forum, blog, or social media post.
We may display parts of your public profile and other Content you make available to the public like Listing details on third-party sites, platforms, and apps.
Information you share publicly on the ROMIO Platform may be indexed through third-party search engines. In some cases, you may opt-out of this feature in your account settings.
4.4 Host Service Providers.
Hosts may use third-party services to help manage or deliver their services, such as cleaning services or lock providers. Hosts may use features on the ROMIO Platform to share information about the Guest (like check-in and check-out information, Guest name, Guest phone number) with such third-party service providers.
4.5 Complying with Law, Responding to Legal Requests, Preventing Harm and Protecting Our Rights.
We may disclose your information to courts, law enforcement, governmental or public authorities, tax authorities, authorized third parties, or other Members, if and to the extent we are required or permitted to do so by law or where disclosure is reasonably necessary to: (i) comply with our legal obligations, (ii) comply with a valid legal request (such as a subpoena or court order) or to respond to claims asserted against romio, (iii) respond to a valid legal request relating to a criminal investigation to address alleged or suspected illegal activity, or to respond to or address any other activity that may expose us, you, or any other of our users to legal or regulatory liability, (iv) enforce and administer our agreements with Members.
Where appropriate, we may notify Members about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon or harm to romio, our Members, or expose ROMIO to a claim of obstruction of justice.
Where legally required or permissible according to applicable law, we may disclose Hosts’ and/or Guests’ information to tax authorities or other governmental agencies for the purpose of the tax authorities’ determination of proper compliance with relevant tax obligations. Relevant tax obligations include romio’s tax obligations on its service fees, its facilitation of taxes on accommodations and withholding taxes, and Hosts’ individual tax obligations. Information that may be disclosed includes, but is not limited to, Host and Guest names, listing addresses, Host addresses, tax/business identification number(s), date of birth, and/or contact information, property parcel identification numbers, payout information, transaction dates and amounts, number of nights and Guests booked, gross and net booking value and payout amounts, taxes collected by ROMIO on behalf of Guests and Hosts, to the extent any of this information is known by romio.
In jurisdictions where ROMIO facilitates or requires a registration, notification, permit, or license application or number of a Host with a governmental authority, we may share information of participating Hosts with the relevant authority, both during the application process, when the Listing is published, and periodically thereafter, such as the Host’s full name and contact details, Accommodation address, tax identification number, registration, permit, or license number, Listing details, reservation information, and number of nights booked subject to applicable laws.
4.6 Programs with Managers and Owners.
We may share personal information of Hosts and Guests with landlords, management companies, homeowners' associations, property owners, and/or property managers ("Building Management"), such as booking information and information related to compliance with applicable laws, in order to facilitate programs with Building Management. For example, guest booking and personal information, including guest contact information, may be shared with the Building Management of the building, complex, or community where a host lives and/or the listing is located to facilitate hosting services, compliance with applicable laws, security, billing, and other services.
4.7 Host Information Provided to ROMIO for Work Customers.
If a booking is designated as being for a business or work purpose and (1) is made by a Guest affiliated with an Enterprise and (2) the Enterprise is enrolled in ROMIO for Work, we may disclose information related to the booking to the Enterprise (e.g., name of the Host, Accommodation address, booking dates, Listing details, etc.) to the extent necessary for the adequate performance of romio’s contract with the Enterprise and to provide the services. At the request of the Enterprise or the Guest, we may also share this information with third parties engaged by the Enterprise to provide support services.
4.8 Service Providers.
We share personal information with affiliated and unaffiliated service providers (including their service providers) to help us run our business and for their compliance purposes, including those that help us: (i) verify your identity or authenticate your identification documents, (ii) check information against public databases, (iii) conduct background checks, fraud prevention, security investigations, and risk assessments, (iv) perform product development, maintenance, and debugging, (v) allow the provision of the ROMIO Services through third-party platforms and software tools (e.g., through the integration with our APIs), (vi) provide customer service, advertising, or payments services, (vii) offer additional services you select, (viii) process, handle, or assess insurance claims or similar claims, or (ix) review, scan, and analyze communications on the ROMIO Platform for certain purposes (such as evidence of child exploitation). See the Analyzing and Sharing Your Communications section for additional information. These providers are contractually bound to protect your personal information and have access to your personal information to perform these tasks. Other Members can use services other than ROMIO to process your data. These can include email or reservation management software. Such services are outside of romio’s control and will be subject to applicable laws around the world with varying levels of data protection.
4.9 Business Transfers.
4.10 Corporate Affiliates.
To support us in providing, integrating, promoting and improving the ROMIO Platform, Payment Services, and our affiliates’ services, we may share personal information within our corporate family of companies that are related by common ownership or control. Some examples are:
- Sharing with romio, Inc. Even if your country of residence is not the United States, your information will be shared with romio, Inc., which provides the technical infrastructure for the ROMIO Platform.
- Sharing with ROMIO Payments. In order to facilitate payments on or through the ROMIO Platform.
- Sharing with ROMIO Ireland. Even if your country of residence is outside EEA (e.g., United States, Japan, China) your information may be shared with ROMIO Ireland, which provides customer support and other business operation services to other ROMIO entities and may be disclosed in line with section 4.5 above.
- Sharing with ROMIO GSL. Even if your country of residence is not Japan, your information may be shared with ROMIO GSL, which provides customer support and other business operation services to other ROMIO entities.
5. OTHER IMPORTANT INFORMATION
5.1 Third-Party Partners & Integrations.
Parts of ROMIO may link to third-party services. ROMIO does not own or control these third parties. When you interact with these third parties and choose to use their service, you are providing your information to them.
6. YOUR RIGHTS
You can exercise any of the rights described in this section consistent with applicable law. We may ask you to verify your identity and request before taking further action on your request.
6.1 Managing Your Information.
You can access and update some of your personal information through your Account settings. If you connected your ROMIO Account to a third-party service, like Facebook or Google, you can change your settings and unlink from that service in your Account settings. You are responsible for keeping your personal information up to date.
6.2 Data Access and Portability.
In some jurisdictions, applicable law may entitle you to request certain copies of your personal information or information about how we handle your personal information, request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format, and/or request that we transmit this information to another service provider (where technically feasible).
6.3 Data Erasure.
In some jurisdictions, you can request that your personal information be deleted. Please note that if you request deletion of your personal information, or if your account is suspended, terminated, or voluntarily closed:
- We may retain your personal information as necessary for our legitimate business interests, such as prevention of money laundering, fraud detection and prevention, and enhancing safety. For example, if we suspend an ROMIO Account for fraud or safety reasons, we may retain information from that ROMIO Account to prevent that Member from opening a new ROMIO Account in the future.
- We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, ROMIO and ROMIO Payments may keep information for tax, legal reporting, and auditing obligations.
- Information you have shared with others (e.g., Reviews, forum postings) may continue to be publicly visible on romio, even after your ROMIO Account is canceled.
- Because we take measures to protect data from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.
Delete my account and data:
While no organization can guarantee perfect security, we are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unlawful or unauthorized access, loss, destruction, or alteration.
9. CONTACT INFORMATION AND RESPONSIBLE ROMIO ENTITIES