Privacy Policy
Last updated: March 14, 2022
Onetwotrail exists to help connect people and build a more open and inclusive world. In short, to build a world where we all feel at home wherever we go. Our community is built on trust. To earn it, it is essential that we are transparent about how we use your data and how we protect your human right to privacy.
This Privacy Policy describes how Onetwotrail, S.A. and its affiliated companies ("we," "our, our(s), us," or "onetwotrail"), treat personal data in connection with your use of the Onetwotrail Platform. Depending on where you live and what you are doing on the Onetwotrail Platform, the supplemental privacy pages listed below may apply to you. Please follow the links and review the supplemental information that describes how we process personal information for those regions and services.
1. DEFINITIONS
Undefined terms in this Privacy Policy have the same definition as in our Terms of Service ("Terms").
2. PERSONAL INFORMATION WE COLLECT
2.1 Information necessary to use the Onetwotrail Platform.
We collect personal information about you when you use the onetwotrail platform. Without it, we may not be able to provide all of the services you request. This information includes the following:
- Contact Information, Account, Profile Information. Such as your first name, last name, phone number, email address, some of which will depend on the features you use.
2.2 Information Collected Automatically through the Onetwotrail Platform and our Payment Services.
When you use the Onetwotrail Platform and the Payment Services, we collect Personal Information automatically. This information may include the following:
- Geographic Location Information.Such as precise or approximate location, determined from your mobile device's IP address or GPS, depending on your device settings. We may also collect this information when you are not using the App if you enable it through your device settings or permissions.
Usage information. Such as the pages or content you view, Ad searches, bookings made and other actions taken on the Onetwotrail Platform.
Log Data and Device Information. For example, details about your use of the Onetwotrail Platform (including whether 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, error data, cookie data, and the pages you viewed or interacted with before or after using the Onetwotrail Platform. We may collect this information even if you have not created an onetwotrail account or logged in.
Cookies and Similar Technologies, as described in our Cookie Policy.
Payment Transaction Information. Such as the payment instrument used, date and time, payment amount, payment instrument expiration date and billing zip code, PayPal email address, IBAN information, your address and other details related to the transaction.
2.3 Personal Information We Collect from Third Parties. We collect personal information from other sources, such as:
Third Party Services. If you link, connect or log in to the onetwotrail Platform with a third party service (e.g., Google, Facebook or Apple), you instruct that service to send us information, such as your registration, friends list and profile information, as controlled by such service or as authorized by you through such service's privacy settings.
Background Information.
For Members in the United States, to the extent permitted by applicable law, we may obtain, for example, criminal history reports, sex offender registries, and other information about you and your background. For Members outside the United States, to the extent permitted by law, and with your consent where required, we may obtain the local version of a criminal background check or sex offender registry. 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 business products may send personal information to facilitate account management and invitations to use business products.
Invitations and Travel Partners. If you are invited to the onetwotrail Platform as a travel companion, the person who invited you may send personal information about you, such as your email address or other contact information.
Otras fuentes. En la medida en que lo permita la legislación aplicable, es posible que recibamos información adicional sobre usted, como referencias, datos demográficos o información para ayudar a detectar el fraude y los problemas de seguridad por parte de terceros proveedores de servicios o socios y la combinemos con la información que tengamos sobre usted. Por ejemplo, podemos recibir resultados de verificaciones de antecedentes o advertencias de fraude por parte de proveedores de servicios de verificación de la identidad para utilizarlos en nuestros procesos de evaluación de riesgos. Es posible que recibamos información sobre usted y sus actividades dentro y fuera de la Plataforma onetwotrail o sobre sus experiencias e interacciones con nuestros socios. Podemos recibir información de salud, incluyendo, pero no limitados a, información de salud relacionada con enfermedades contagiosas.
3. HOW WE USE THE COLLECTED INFORMATION
3.1 To Provide, Improve and Develop the onetowtrail Platform. Among other purposes, we use personal
personal information to:
enable you to access the onetowtrail Platform and make and receive payments,
enable you to communicate with other Members,
process your requests,
perform analysis, debugging and research,
provide customer service, trainings,
send you messages, updates, security alerts and account notifications,
if you provide us with your contact information, such as your friends or travel companions, we may process this information to: (i) facilitate invitations, (ii) share your trip details and facilitate trip planning, (iii) detect and prevent fraud, and (iv) facilitate applications or any other purpose you authorize, to configure and personalize your experience based on your interactions with the onetwotrail Platform, your search and booking history, your preferences and profile information, and other content you submit; and enable the use of our business products.
3.2 Create and maintain an environment of trust and security. Among other purposes, we use personal information for:
detecting and preventing fraud, spam, abuse, security incidents and other harmful practices,
study and combat discrimination in accordance with our Anti-Discrimination Policy,
conduct security investigations and risk assessments,
verify or authenticate information you provide,
conduct checks against databases and other sources of information, including background or police checks,
comply with our legal obligations, protect the health and welfare of our Guests, Hosts, Host employees and members of the public,
resolve disputes with our Members, including sharing information with your co-Host or additional Guests about disputes related to your role as a co-Host or additional Guest,
enforce our agreements with third parties,
comply with the law, respond to legal requests, prevent harm and protect our rights (see section 4.5).
enforce our Terms and other policies (e.g., the Anti-Discrimination Policy), and in connection with the foregoing activities, we may conduct profiling based on your interactions with the onetwotrail Platform, your profile data and other content you submit to onetwotrail and information obtained from third parties. In specific cases, automated processes, which analyze your account and activities on the onetwotrail Platform, as well as information related to activities on and off the onetwotrail Platform that may be associated with you, may restrict or suspend access to the onetwotrail Platform if such processes detect activities that may pose a security or other risk to onetwotrail, our community or third parties. If you would like to challenge decisions based on automated processes, please contact us through the Contact Information section below.
3.3 To provide, personalize, measure and improve our advertising and marketing. We use personal information for example 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 operated by onetwotrail or its third party business partners,
analyze characteristics and preferences to send you promotional messages, marketing, advertising and other information that we believe may be of interest to you and invite you to relevant events and opportunities.
invite you to relevant events and opportunities.3.4 Providing Paid Services. Personal Information is used to allow or authorize third parties to use the Paid Services, among other things to
Use of the Payment Services, among other purposes:
detecting and preventing money laundering, fraud, abuse and security incidents,
conducting security investigations and risk assessments,
comply with legal obligations (such as anti-money laundering provisions),
enforce the Payment Terms and other payment policies,
with your consent, send you promotional messages, marketing, advertising and other information that may be of interest to you based on your preferences, and provide and improve the Paid Services
4. SHARING AND DISCLOSURE OF INFORMATION
4.1 Information provided with your consent or at your request.
When you have given your consent, we share your information as described at the time of such consent, such as when we authorize a third party application or website to access your onetwotrail account or when we participate in promotional activities of onetwotrail partners or third parties.
Where permitted by applicable law, we may use certain information about you, such as your email address, de-identify it and share it with social media platforms, to generate leads, drive traffic to onetwotrail or promote our products and services.
4.2 Information Shared Among Members.
To help facilitate reservations or other interactions between Members, we may need to share certain information, such as:
When a reservation request is made, when a co-host exists or a dispute is submitted, certain information may be shared between Members and Customers, including profile, name, names, names of any additional Members, cancellation history, rating information, age of Member (unless prohibited by applicable law), dispute outcome (where applicable) and any other information you choose to share and submit. When the reservation is confirmed, additional information is shared to help coordinate travel, such as profile picture or phone number. When you have a confirmed booking as a Customer, certain information is shared with the User (and any additional Users you invite, if applicable) to coordinate the booking, such as your profile, your full name, your phone number and the address of your Advertisement.
Each time you, as a Customer, invite another Member to host Users with you, you authorize that person to access and update your information and Member Content, including but not limited to certain information, such as your full name, phone number, Experience address, calendar, Ad information, Ad photos, and email address.
Each time you, as a User, invite an additional User to a reservation, we will provide the additional Users with your first and last name, the dates of travel, the Customer's name, the details of the Advertisement, the address of the Experience and other related information.
4.3 Information You Post in Profiles, Announcements and Other Public Information. You may allow certain information to be visible to the public, such as:
Your public profile page, which includes your profile picture, your name (or initials, where applicable), a description, and your city.
Listing pages containing information such as the approximate or exact location of the Lodging or Experience, date availability, profile photo, aggregate demand information (such as page views over a period of time), and additional data you choose to share.
Evaluations, ratings and other public comments.
Content in a community or discussion forum, blog or social media posting.
We may display portions of your public profile and other Content you make publicly available, such as Ad details on third party sites, platforms and applications.
Information you share publicly on the Onetwotrail Platform may be indexed through third party search engines. In some cases, you can disable this feature in your Account settings.
4.4 Host Service Providers.
Customers may use third party services to manage or provide their services, such as cleaning or security service providers. Customers may use the onetwotrail Platform features to share information about the User (such as arrival and departure dates, the User's name and phone number) with such third party service providers.
4.5 To comply with the law, respond to lawful requests, prevent harm and protect our rights.
We may disclose your information to courts, law enforcement, governmental or public authorities, tax authorities or authorized third parties to the extent we are required or permitted by law or when 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 respond to claims made against Onetwotrail; (iii) respond to a valid legal request in connection with a criminal investigation to address suspected illegal activity, or respond to any other activity that may expose us, you or any of our other users to legal or regulatory liability; (iv) enforce and administer our agreements with Members, including our Terms, Additional Legal Terms and Policies; or (v) protect the rights, property or personal safety of Onetwotrail, its employees, Members, or members of the public.
Where applicable, we may notify Members of legal requests unless: (i) notification is prohibited by the legal process itself, by a court order received or by applicable law, or (ii) we believe that providing notification would be futile, ineffective, cause a risk of injury or bodily harm to a person or group, create or increase a risk of fraud or harm to Onetwotrail, our Members, or expose Onetwotrail to a claim of obstruction of justice.
Where required or permitted by law, in accordance with applicable law, we may disclose Customer and/or User information to tax authorities in order for them to determine whether they are properly complying with applicable tax obligations. Applicable tax obligations include Onetwotrail's tax obligations on its service fees.
In jurisdictions where Onetwotrail facilitates or requires a Customer's registration, notification, permit or license application or number with a governmental authority, we may share participating Customer information with the relevant authority, both during the application process, when the Advertisement is posted, and periodically, such as the Customer's full name and contact details, Experience address, tax identification number, registration, permit or license number, Advertisement details, the reservation information and the number of nights reserved subject to the provisions of applicable law.
4.6 Programs with Managers and Owners.
We may share Customers' and Users' personal information with owners, management companies and/or property owners ("Pool Management"), such as reservation information and information related to compliance with applicable laws, in order to facilitate programs with Pool Management. For example, personal information and guest reservations, including guest contact information, may be shared with Consortium Management of the building, complex or community in which the host lives or in which the accommodation is located, to facilitate host services, compliance with applicable laws, security, billing and other services.
4.7 Service Providers.
We share personal information with affiliated and unaffiliated service providers to help us administer our business and for their purposes of complying with applicable regulations, including service providers that help us to: (i) verify your identity or authenticate your identification documents, (ii) match information against public databases, (iii) conduct background or police checks, fraud prevention and risk assessment,(iv) develop, maintain and debug products, (v) enable the delivery of the onetwotrail Services through third party platforms and software tools (e.g., through integration with our APIs), (vi) provide customer service, advertising or payment services, (vii) process, manage or evaluate insurance claims or similar claims, or (viii) facilitate charitable and non-profit activities consistent with onetwotrail's mission. These vendors are contractually obligated to protect your personal information and have access to your personal information to perform these tasks.
4.8 Business Transfers.
If onetwotrail conducts or participates in any merger, acquisition, reorganization, asset sale, bankruptcy or insolvency event, we may sell, transfer or share some or all of our assets, including your information in connection with such transaction or with a view to such transaction (e.g., in a buyout audit). In such an event, we will provide you with notice before your personal information is transferred and becomes subject to a different privacy policy.
4.9 Business Partners.
To help us provide, integrate, promote and improve the Onetwotrail Platform, the Payment Services and our affiliates' services, we may share personal information with our corporate family of companies that are related by common ownership or control. Examples include:
Data shared with Onetwotrail, S.A. Even if your country of residence is not the United States, your data will be shared with Onetwotrail, S.A. which provides the technical infrastructure for the Onetwotrail Platform.
Data shared with Onetwotrail. To facilitate payments on or through the Onetwotrail Platform, certain information set forth in the "Outside the United States" section will be shared with the Onetwotrail entity.
5. OTHER IMPORTANT INFORMATION
5.1. Analysis of Your Communications.
We may review, scan or analyze your communications on the Onetwotrail Platform for the reasons described in the "How We Use the Information We Collect" section of this policy, including for fraud prevention, risk assessment, regulatory compliance, research, product development, studies, analysis, compliance with our Terms of Service, and customer service. For example, as part of our fraud prevention efforts, we review and analyze messages to hide contact information and references to other websites. In some cases, we will also inspect, review, or analyze messages to refine, improve, and enhance product offerings. We use automated methods when reasonably possible. Occasionally, however, we may need to manually review some communications, such as fraud investigations and customer service, or evaluate and improve the functionality of these automated tools. We will not review, screen or analyze your communications to send you third-party marketing messages, and we will not sell evaluations or analyses of these communications.
5.2 Linking Third Party Accounts.
You may link your onetwotrail account with certain third party services, such as social networks. Your contacts on these third party services are called "Friends". When you allow the communication of data when linking such accounts:
some of the data you provide to us when linking accounts may be published on your public profile,
your activities on the Onetwotrail Platform may be shown to your Friends on the Onetwotrail Platform and/or on the third party service,
a link to your public profile on the third party service may be included in your onetwotrail public profile,
other onetwotrail 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 onetwotrail users may see any school, hometown or other group you have in common with them that appears on your linked social networking service,
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 the information you provide to the Onetwotrail Platform through this linking is subject to the settings and authorizations you have set up on both the Onetwotrail Platform and the external service.
5.3 External partners and integrations.
Some parts of onetwotrail may link to third party services that onetwotrail does not own or control, such as Google Maps/Earth, Here API, Green Pay API. Use of these services is subject to the privacy policies of those providers, such as the Google Maps/Earth Additional Terms of Use, Google's Privacy Policy (learn more about how Google uses information here) and Citi's Privacy Policy. Onetwotrail does not own or control these third parties, and when you interact with them, you provide them with your information.
6. YOUR RIGHTS
You may exercise any of the rights described in this section in accordance with applicable law. Here you can obtain information about the data subject's rights requests and the submission of requests. Please note that we may ask you to confirm your identity before processing the request.
6.1 Managing your information.
You can access and update some of your personal information through your Account settings. If you connected your onetwotrail account to a third party service, such as Facebook or Apple, you can modify your settings and disassociate yourself 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 regions, applicable law may give you the right to request certain copies of your personal data or data about how we process your personal data, request copies of the personal data you have provided to us in a structured, commonly used, machine-readable format, and/or request that we transmit this information to another service provider (where technically feasible).
6.3 Deletion of data.
In certain jurisdictions, you may request that your personal data be deleted. Please note that if you request deletion of your personal data or if your account is suspended, deleted or voluntarily closed:
We may retain your personal information as necessary for our legitimate business interests, such as money laundering prevention, fraud detection and prevention, and security enhancement. For example, if we suspend an onetwotrail account for fraud or security reasons, we may retain information from that oentwotrail account to prevent that Member from re-opening a new onetwotrail account in the future.
We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, onetwotrail may retain your information to comply with tax, legal and auditing obligations.
Information you have shared with others (e.g., ratings, forum postings) will remain publicly visible on onetwotrail, even after you cancel your onetwotrail account. However, attribution to you of such information will be removed. Some copies of your information (e.g., logs) may remain in our database, but are disassociated from any personal identifiers.
Because we take measures to protect data from accidental or malicious loss and destruction, residual copies of your information may not be deleted from our backup systems for a certain period of time.
7. SECURITY
We continuously implement and update security measures, including administrative, technical, and physical safeguards, to protect your information against any unauthorized access, loss, destruction, or alteration.
8. MODIFICATIONS TO THIS PRIVACY POLICY
We reserve the right to modify this Privacy Policy at any time, in accordance with applicable law. If we do so, we will post the modified Privacy Policy and update the "Last Updated" date indicated at the top. In the event of significant changes, we will also notify you of the modifications via email at least thirty (30) days before the effective date. If you do not agree with the modified Privacy Policy, you may cancel your account. If you do not cancel your account with onetwotrail before the effective date of the modified Privacy Policy, any access or use of the Onetwotrail Platform you undertake thereafter will imply your acceptance of it.
9. CONTACT INFORMATION AND ENTITIES RESPONSIBLE FOR ONETWOTRAIL
If you have any questions or complaints about this Privacy Policy or the treatment of personal information by onetwotrail (i) If you reside in Costa Rica, please contact Onetwotrail, S.A., San Rafael de Montes de Oca, San José, Costa Rica.