INTRODUCTION
This privacy policy (“Privacy Policy”) governs how we, Room Speculator LLC. (together, “RoomSpeculator” “we”, “our” or “us”) use, collect and store Personal Data we collect or receive from or about you (“User”,“you”), including when you (i) use or visit the website, www.roomspeculator.com and its subdomains (collectively, the Site, and (ii) when you otherwise interact with us, including when you make a hotel reservation through Room Speculator or make inquiries or request support from our customer services representatives. When used in this Privacy Policy, “Personal Data” means any information that relates to a natural person who has been identified or is identifiable using the information we have collected or received. We have implemented this Privacy Policy because your privacy, and the privacy of other users, is important to us. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to Personal Data. We may update this Privacy Policy from time to time. We therefore recommend that you check back from time to time to review the latest version of this Privacy Policy. If our practices with respect to your Personal Data change significantly, we will notify you either by posting a notice on the Site or by other means.We do not ourselves host the Site, all hosting is done by third-party service providers that we engage. These service providers often store data on servers in other countries, including in the United States. So please be aware that, to the maximum extent permitted by law, you are acknowledging and/or consenting to your data being transferred to various third party service providers around the world (including the US) as indicated below.
The table below provides a simple description of the type of Personal Data that we collect and process through the Service, the purpose of our processing of this data, the legal basis we have for doing so, third parties with whom we share the data, how long we store the data, and what the consequences would be if we did not receive or were unable to process this data. Further below you may also find additional information about how we process Personal Data.
Data we collect
We use various types of Cookies for a variety of purposes. Please see our Cookies Policy for more information.
Depending on the Cookie type and purpose, the legal basis will be different. Typically, the legal basis for essential cookies is either legitimate interest or performance of a contract (e.g. to deliver the website to you). The legal basis for non-essential cookies is consent. Please see our Cookies Policy for more information.
We use Cookies provided by various third party partners, and use third-party service providers to process or implement Cookies and the data collected by means of a Cookie. Please see our Cookies Policy for more information.
We use various types of Cookies for a variety of purposes. The period for which a Cookie is stored will depend on the Cookie type. Please see our Cookies Policy, for more information.
Depending on the type of the Cookie, an inability to use a Cookie will have different consequences, such as an inability to collect and store the information, or to enable use and access of various parts of the Site or provide the Service.
Data we collect
When you create an account we receive and store the following information: First name, Last name, Email address, Phone number
If you create an account or log-in to the Site using your Facebook or Google accounts, we receive and store the following information: First name, Last name, Email address
To create the account and provide you with the Service.
Please note that when you make or cancel a reservation, make a special request, or take other action in connection with your account (for example, while logged in) this data may be associated with your account. Your account information will also be used for the purpose of the reservation, cancellation, special request, etc. as associated as described in this table.
Depending on the context, performance of a contract (providing you the Service per the Terms of Use); Legitimate interest (providing you the Service or processing your requests); or Consent (e.g. for special categories of data).
This information is shared with 3rd party providers of customer support services as well as in the context of other activities (for example, making or selling a reservation, cancelling a reservation, etc.) as described in this privacy policy.
Until your account is deleted.
If mandatory information is not provided, the account will not be created and certain other features of the Website which require an account (and other features or services we offer which require an account) will be unavailable to you.
Failure to provide other non-mandatory information may result in an inability of Room Speculator to contact you, including in connection with information relevant to you.
Data we collect
First name, Nast name, Address, Nationality, Phone number, E-mail address
Reservation details you have chosen or entered such as the hotel, room type, and the number of guests.
Please note: when you make a reservation while logged in to your account, some of the above information may be collected from your account.
To process and handle the booking; Send confirmation to you; Contact you regarding the booking; Process cancellations and obtain refunds (as needed).
Performance of a contract (i.e., the reservation) or processing is necessary in order to take steps at the request of the data subject prior to entering into a contract; or legitimate interest (e.g. processing your requests).
The hotel. Booking agents and resellers of the hotel reservation.
Third-party service providers who provide platforms on which the reservation are offered and sold.
Third-party customer support service providers.
Until your account is terminated or longer as needed in order to identify the reservation and process your requests following check-out, to process refunds (if applicable), comply with our contractual obligations toward 3rd party resellers, booking agents or hotels, and applicable law.
Consequences of not providing the data
Bookings cannot be processed.
Data we collect
Information provided by you in connection with special requests (normally in the designated field in the reservation page).
To process the request and contact you in connection with these requests.
Performance of a contract; Consent (for sensitive data you provide as part of your request).
The hotel, resellers of the hotel reservation and if applicable, third-party service providers who provide platforms on which the reservation are offered and sold.
As needed in order to identify the reservation and process your requests following check-out, to process refunds (if applicable), comply with our contractual obligations toward 3rd party resellers, booking agents or hotels, and applicable law.
Special requests which include sensitive or personal information cannot be processed.
Data we collect
Information provided by you in connection with your request to cancellation the reservation (for example, the reason for the cancellation).
To process the cancellation and contact you in connection with these requests.
Performance of a contract; Consent (for sensitive data you may provide).
The hotel, resellers of the hotel reservation and if applicable, third-party service providers who provide platforms on which the reservation are offered and sold.
As needed in order to identify the reservation and process your requests following check-out, to process refunds (if applicable), comply with our contractual obligations toward 3rd party resellers, booking agents or hotels, and applicable law.
The cancellation may not be processed (depending on the circumstances).
Data we collect
First name, Last name, Email address, Phone number, Zip code, Country of residence
If you pay by credit card, then the name on the card, your credit card information: credit card number, expiration date, security code and billing address.
If you pay using your account with a third-party payments service, Room Speculator will only receive confirmation of the payment, a transaction number and authorization number. Please see Section 3.1 (Payment Services You May Choose) below for more information about how such third-party payment services collect and use your information.
To collect payment for a reservation, confirm your identity and check for credit card fraud.
Performance of a contract (processing the reservation and payment); Legitimate interest (fraud detection and prevention).
3rd party providers of fraud detection and prevention services, such as Riskified Ltd. (https://www.riskified.com/privacy);
These include the following payment processors: BlueSnap, Inc., Stripe, Inc., and Zoopay, Inc. For more information about how we use these processors, please see Section 3.2 (Payment Processers We Use) below.
If you pay using your account with a third-party payments service, Room Speculator will only receive confirmation of the payment, a transaction number and authorization number. Please see Section 3.1 (Payment Services You May Choose) below for more information about how such third-party payment services collect and use your information.
In certain cases, which are indicated on the payment page, your payment information (and payment) will be made directly to a third-party booking agent or reseller of reservations such as Booking.com, who collect payment directly
1. Payment Services You May Choose. If you make a payment on the Site using your account with a third-party service, such as Paypal, Apply Pay or Google Pay, the information you provide in connection with the payment will be collected directly by the third-party service provider (such as Paypal, Apple or Google). Room Speculator will only receive confirmation of the payment, a transaction number and authorization number. To learn more about how such third-party services collect and use your personal information, we encourage you to review their privacy policies and notices. Paypal’s privacy policy is available at: https://www.paypal.com/en/webapps/mpp/ua/privacy-full; Google Pay’s privacy policy is available at https://payments.google.com/legaldocument?family=0.privacynotice&hl=en-GB; and the Apple Pay security and privacy overview is available at Apple Pay: https://support.apple.com/en-il/HT203027.
2. Payment Processors We Use. When you make a payment on the Site, we use a third-party payment or credit card processor to process your credit card purchases. The type of information we collect for billing purposes is described in the table above. In order to process your payments, your billing information will be shared via secure (encrypted) means with a third party credit card processor. We currently engage the following third-party payment processors (or their affiliates) to process payments on our behalf: BlueSnap, Inc., Stripe, Inc., and Zoopay, Inc. In certain cases, such service providers describe how they collect and use information their customers (like us) provide or make available to them. In such cases, we encourage you to read the relevant sections of those privacy policies: BlueSnap’s privacy policy is available at http://home.bluesnap.com/ecommerce/legal/privacy-policy. Stripe’s privacy policy is available at https://stripe.com/us/privacy (customers of ours are referred to as “Customers” in the privacy policy).
We have implemented appropriate technical, organizational and security measures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to such information appropriate to the nature of the information concerned. However, please note that we cannot guarantee that the information will not be exposed as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.
In addition to the retention periods mentioned in Section 1 above, in some circumstances we may store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings.
In addition to the recipients described in Section 1, we may share your information as follows:
To the extent necessary, with governmental or legally-authorized regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies, or if required to do so by court order;
If, in the future, we sell or transfer some or all of our business or assets to a third party, we will (to the minimum extent required) disclose information to a potential or actual third party purchaser of our business or assets. We may also transfer or assign Personal Data in the event that we are acquired by or merged with a third party entity, or in the event of bankruptcy or a comparable event;
Where you have provided your consent to our sharing of the Personal Data (e.g., where you opt-in to receive certain services, functionality or messages, or click a check box adjacent to a sentence consenting to a particular use of your Personal Data); and
Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Data is disclosed.
When your Personal Data is transferred to and between our affiliates and subsidiaries, we ensure that those transfers are subject to an agreement which contractually obliges the recipient entity to ensure that the Personal Data receives an adequate and consistent level of protection wherever it is transferred to.
If you are an individual protected by the GDPR, where we transfer your Personal Data outside of the European Economic Area we obtain contractual commitments from the recipient of the data to protect your Personal Data and assurances regarding the standards of protection used.
Some of these assurances are well recognized certification schemes like the EU – US Privacy Shield for the protection of Personal Data transferred from within the EU to the United States.
Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Data is disclosed.
Individuals protected by the EU General Data Protection Regulation (GDPR), such as EU Residents, have the following rights, subject to certain exemptions or derogations which may apply: The right to access and receive information we maintain about you.
The right to request that we amend any Personal Data we hold about you that it is inaccurate or misleading.
The right to request the erasure of the Personal Data that relates to you. Please note that there may be circumstances in which we are required to retain your data, for example for the establishment, exercise or defense of legal claims;
The right to object to our processing of your Personal Data or to request a limitation or restriction of the processing. However, there may be circumstances in which we are legally entitled to refuse your request;
The right to “data portability.” This means that you may have the right to receive your Personal Data in a structured, commonly used and machine-readable format, and to transmit that data to another controller;
The right to object to profiling;
The right to lodge a complaint with your local data protection supervisory authority (i.e., in your place of habitual residence, place or work or place of alleged infringement). We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority.
The right to withdraw your consent to our processing of your Personal Data. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations.
The right to request details of the basis on which your Personal Data is transferred outside the European Economic Area, but you acknowledge that data transfer agreements we may send you may need to be partially redacted for reasons of commercial confidentiality.
You can exercise your rights by contacting us at privacy@roomspeculator.com. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfill your request. When processing your request, we may ask you for additional information to confirm your identity and for security purposes, before disclosing the Personal Data requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
We do not offer our products or services for use by children. If you are under 18, you may not use the Service, or use our other products and services, or provide any information to us without involvement of a parent or a guardian. We do not knowingly collect information from, and/or about children.
Some of your activity on and through the Service is or becomes publicly available on the Website by default. This may include, but is not limited to, content you have posted publicly on the Website (such as on forums, comments sections or message boards) or otherwise through the Service. The Service may also enable you to create a public profile as part of your Account. In such case, certain Account information (such as a username and profile picture) may be publicly available. In addition, information you post on the Service may be associated with your Account (including the user name of the Account). Individuals reading information made publicly available may use or disclose it to other individuals or entities without our control and without your or our knowledge, and search engines may index that information. We therefore urge you to think carefully before including any specific information you may deem private in content you submit through the Service.
You may request the deletion of your Account by emailing your request to support@roomspeculator-customers.com. If you terminate your Account, any association between your Account and information we store will no longer be accessible by you through your Account. However, any information you have provided or which is associated with your Account which has been made publicly available will remain stored on our servers and will remain accessible to the public.
If you would like to access, delete or correct any of your other Personal Information that we may be storing, you may use the tools that we make available on the Service or you may submit a request by sending an email to support@roomspeculator-customers.com. We will make commercially reasonable efforts to respond to your request.
The Website may enable you to interact with or contain links to your third party websites or services, including those for which you may have an account, that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services may collect Personal Information from you. Accordingly, we encourage you to read the terms and conditions and privacy policy of each Third Party Service that you choose to use or interact with.
You may choose not to receive emails from us by selecting an unsubscribe link at the bottom of each email that we send. Please note that even if you opt-out of receiving emails, we may still send you a response to any “Contact Us” request as well as administrative emails that are necessary to facilitate your use of the Service or requests you may make (such as confirmation emails with your booking information).
We use log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We may use such information to analyze trends, administer the Service, track users’ movement around the Service, and gather demographic information.
Our collection of information involves cookies, anonymous identifiers and other tracking technologies. These enable us to provide our Site, present you with information and options that are customized for you and provide us with other information about how the Site is used. A “cookie” is a small text file that may be used, for example, to collect information about activity on the Site. Certain cookies and other technologies may serve to recall Personal Information, such as an IP address, previously indicated by a user. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser. Please review our Cookie Policy at www.roomspeculator.com/cookie-policy for more information about Cookies and how they are used as part of the Service.
We may collect and analyze information about use of the Website using cookies and other tracking technologies and services provided by third parties (collectively, “Analytics Services”), such as (but not limited to) Google Analytics and Hotjar (as described in further detail below). Analytics Services collect information about activities on the Site, such as what users do on the Site, what elements of the site are interacted with, how often users visit the Site, what pages of the Site they visit, what other websites they may have used prior to coming to the Site, what search engine and search keywords they may have used to get to the Site, and information about users’ devices and browsers. We use this information to maintain and improve the Site and our products and services. Collection and analysis of user activity on the Website involves the use of cookies. Please read our Cookies Policy for information about how we use, collect and analyze data through the use of Cookies.
15.1. Google Analytics. Google Analytics collects information such as how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this Site. We use the information we get from Google Analytics to maintain and improve the Site and our products. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Service, available at http://www.google.com/analytics/terms/us.html/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.
15.2. Hotjar. Hotjar is provided and hosted by HotJar Ltd. Hotjar is used to evaluate and analyze user activity on the Site and receive feedback from users. Hotjar receives information about your activity on the site, your IP address (collected and stored in anonymous format)device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our website), log data such as the domain you visited which referred you to our Site, and which pages you visit on the Site and the time of the visits. HotJar also uses cookies to collect non-Personal Information such as standard internet log information details of activity on the Site, and to record log in details to avoid having to repeatedly log in to the Site. To learn more about how HotJar collects and uses information from your visit to the Site, please visit: https://help.hotjar.com/hc/en-us/articles/115011639887-Data-Safety-Privacy-Security. You may also disable Hotjar’s collection of date in connection with you here: https://www.hotjar.com/legal/compliance/opt-out. Most browsers enable you to block the use of such cookies, but doing so may impact the functionality of the Site.
If you are a California resident the following applies to you:
16.1. Disclosure of Direct Marketing Practices. California Civil Code Section 1798.83 permits you to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@roomspeculator.com. Please note that we are only required to respond to one request per customer each year.
16.2. Removal of Public Personal Information. If you are under the age of 18 and a registered user, California Business and Professions Code Section 22581 permits you to remove content or Personal Information you have publicly posted. To remove, please follow these instructions: https.//www.roomspeculator.com/personal-details or by sending us a request by email to support@cancelon.com. Please be aware that after removal you will not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or Personal Information you have posted and that there may be circumstances in which the law does not require us to enable removal of content.
Other than identifying the URL of the webpage you visited prior to your visit to the Site (the “referral page”), we do not collect personally identifiable information about an individual consumer’s online activities over time and across different web sites (other than our Site) when a consumer uses our Site. We may allow third parties (such as analytics service-providers like Google and HotJar, as well as Paypal) to collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Site. We do not currently respond or take any action with respect to web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party web sites or online services.
If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at: privacy@roomspeculator.com