“Hosting Power Limited” means the company (company number 545052) which operates through its website www.hostingpower.ie (the “Website”) and is the data controller (the “Data Controller”) for the purposes of the Data Protection Acts 1988 and 2003 (the “Data Protection Acts”).
“Services” means acting as intermediary between the customers of the data controller and potential hosts, and on acceptance by both parties of the hosting arrangement, placing the customers of the data controller and potential host in contact.
“Customers” are the subject of data for the purpose of the Data Protection Acts (hereinafter called the “Data Subject”).
Data Collected By The Data Controller
“Personal Data” means data relating to a living individual who is or can be identified either from the data or from the data in conjunction with other information that is in, or is likely to come into, the possession of the Data Controller.
“Non-Personal Data” means data that is not Personal Data.
“Data” means Personal Data and Non-Personal Data.
“Credit and Debit Card Details” means payment information details, credit and debit card numbers and bank details stored and encrypted in a PCI compliant data centre, managed by Stripe Payments UK Limited.
1. INFORMATION WE COLLECT
There are three general categories of information we collect.
1.1 Information You Give to Us.
1.1.1 Information that is necessary for the use of our services on the Hosting Power Website.
We ask for and collect the following personal information about you when you use the Hosting Power website. This information is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all the requested services.
Host Information. When you apply to become a host with Hosting Power, we require certain information such as your first name, last name, email address, home address, phone number and date of birth.
Host Profile and Listing Information. When you agree to become one of our hosts we collect information from you in order to create your online listing. We ask you to provide a description of your listing, the room you are renting as well as a description of yourself as a host and the area you are hosting in. We may ask you to provide additional information, which may include your address and phone number.
Student Identity Verification Information. To help create and maintain a trusted environment, we ask you to give us some identity verification information (such as images of your government issued ID, passport, national ID card, or driving license, as permitted by applicable laws) or other authentication information.
Student Payment Information. To book your room through Hosting Power, we require you to provide certain financial information (like your bank account or credit card information) in order to facilitate the processing of payments via Stripe. We also require that you tell us about the studies/internship you are taking part in in Ireland (location/college, duration of studies/internship etc).
Communications with Hosting Power. When you communicate with Hosting Power we collect information about your communication and any information you choose to provide.
1.1.2 Information you choose to give us.
When applying to become a host you may choose to provide us with additional personal information in order to enhance the quality of your listing. This additional information will be processed based on your consent.
Additional Profile Information. You may choose to provide additional information to be added as part of your listing (such as gender, additional relevant personal details about you as a host or about your listing). This information will be part of your public profile page, and will be publicly visible to others.
Additional Student Information. Students may choose to provide us information when making a booking. This may be additional information about their stay in Ireland and their studies/internship.
1.1.3 Information that is necessary for the use of the Payment Services (Stripe).
The Payments Data Controller needs to collect the following information, as it is necessary for the adequate performance of the contract with you and to comply with applicable law (such as anti-money laundering regulations). Without it, you will not be able to book accommodation with Hosting Power:
Payment Information. When you use the Payment Services (Stripe), the Payments Data Controller requires certain financial information (like your bank account or credit card information) in order to process payments and comply with applicable law.
Identity Verification and Other Information. The Payments Data Controller may require identity verification information (such as images of your government issued ID, passport, national ID card, or driving license) or other authentication information, your date of birth, your address, email address, phone number and other information in order to verify your identity, provide the Payment Services to you, and to comply with applicable law.
1.2 Information We Automatically Collect from Your Use of the Hosting Power Website and Payment Services (Stripe).
When you use the Hosting Power Website and the Payment Services, we automatically collect information, including personal information, about the services you use and how you use them. This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of the Hosting Power website and Payment Services (Stripe).
Geo-location Information. When you use certain features of the Hosting Power website, we may collect information about your precise or approximate location as determined through data such as your IP address.
Usage Information. We collect information about your interactions with the Hosting Power Website, such as the pages or content you view, your searches for Listings, bookings you have made, and other actions on the Hosting Power website.
Log Data and Device Information. We automatically collect log data and device information when you access and use the Hosting Power website. That information includes, among other things: details about how you’ve used the Hosting Power website (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, cookie data, and the pages you’ve viewed or engaged with before or after using the Hosting Power website.
Payment Transaction Information. Hosting Power Payments collect information related to your payment transactions through the Hosting Power website, including the 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. This information is necessary for the adequate performance of the contract between you and Hosting Power to allow the provision of the Payment Services (Stripe).
1.3 Information We Collect from Third Parties.
Hosting Power may collect information, including personal information, about you through third parties.
Third Party Services. If you click on a link through Facebook, Instagram, Twitter, or another third party website, the third party service may send us information such as your registration and profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.
Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or fraud detection information, from third party service providers and/or partners, and combine it with information we have about you. For example, we may receive background check results (with your consent where required) or fraud warnings from service providers like identity verification services for our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the Hosting Power website through third parties.
2. HOW WE USE THE INFORMATION WE COLLECT
We use, store, and process information, including personal information, about you to provide, understand, improve, and develop the Hosting Power website and our services to you, to create and maintain a trusted and safer environment and comply with our legal obligations.
2.1 Provide, Improve, and Develop the Hosting Power Website.
Enable you to access and use the Hosting Power Website.
Operate, protect, improve, and optimize the Hosting Power Website experience, such as by performing analytics and conducting research.
Provide customer service.
Send you service or support messages, updates, security alerts, and notifications.
If you provide us with your contacts’ information, we may process this information: (i) to send you requests for references, (ii) for fraud detection and prevention, and (iii) for any other purpose you authorize at the time of collection.
We process this information given our legitimate interest in improving the Hosting Power website and where it is necessary for the adequate performance of the contract with you.
2.2 Create and Maintain a Trusted and Safer Environment.
Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity.
Conduct security investigations and risk assessments.
Verify or authenticate information or identifications provided by you (such as to verify your Accommodation address or compare your identification photo to another photo you provide).
Conduct checks against databases and other information sources, including background or police checks, to the extent permitted by applicable laws and with your consent where required.
Comply with our legal obligations.
Resolve any disputes with between any of our hosts and students.
Enforce our Terms & Conditions set out in our FAQ section.
In connection with the activities above, we may conduct profiling based on your interactions with the Hosting Power website, your profile information and other content you submit to the Hosting Power website, and information obtained from third parties.
We process this information given our legitimate interest in protecting the Hosting Power website, to measure the adequate performance of our contract with you, and to comply with applicable laws.
2.3 Provide, Personalise, Measure, and Improve our Advertising and Marketing.
Send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences (including information about Hosting Power) and social media advertising through social media platforms such as Facebook, Instagram or Google).
Personalize, measure, and improve our advertising.
Administer referral programs, rewards, surveys,, contests, or other promotional activities or events sponsored or managed by Hosting Power.
We will process your personal information for the purposes listed in this section given our legitimate interest in undertaking marketing activities to offer you products or services that may be of interest to you. You can opt-out of receiving marketing communications from us by following the unsubscribe instructions included in our marketing communications.
2.4 How the Payments Data Controller (Stripe) uses the Information Collected.
Enable you to access and use the Payment Services.
Detects and prevents fraud, abuse, security incidents, and other harmful activity.
Conduct security investigations and risk assessments.
Conduct checks against databases and other information sources.
Comply with legal obligations (such as anti-money laundering regulations).
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.
The Payments Data Controller (Stripe) processes this information given its legitimate interest in improving the Payment Services and its users’ experience with it, and where it is necessary for the adequate performance of the contract with you and to comply with applicable laws.
Data is held on secure servers hosted by Blackknight Internet Solutions Limited and Insightly Inc, of the data controller and host respectively. Data is encrypted using SSL.
3. SHARING & DISCLOSURE
3.1 With Your Consent.
Where you have provided consent, we share your information, including personal information, as described at the time of consent.
3.2 Sharing between Hosts and Students.
To help facilitate bookings or other interactions between hosts and students, we may need to share certain information, including personal information, between hosts and students, as it is necessary for the adequate performance of the contract between you and us, as follows:
When you as a Student submit a booking request, certain information about you is shared with the Host, including your full name, the description you submitted of yourself and the details of your studies/internship along with other information you agree to share. When your booking is confirmed, we will disclose additional information to assist with coordinating your stay, like your email address.
When you as a Host have a confirmed booking, certain information is shared with the Student to coordinate the booking, such as your full name, email address and accommodation address.
We don’t share your billing and payout information between Hosts and Students.
3.3 Profiles, Listings, and other Public Information.
The Hosting Power website publishes your listing profile and that is visible to the general public. For example:
Parts of your public profile page, such as your first name, your listing description, and city, are publicly visible to others.
Listing pages are publicly visible and include information such as the description and approximate location (neighborhood and city), Listing description, calendar availability and any additional information you choose to share.
Based on our legitimate interest to promote the Hosting Power website we may display parts of the Hosting Power website (e.g., your Listing page) on sites operated by Hosting Power’s business partners, using technologies such as widgets or APIs. If your Listings are displayed on a partner’s site, information from your public profile page may also be displayed.
Information that is shared publicly on the Hosting Power website, may be indexed through third party search engines. We do not control the practices of third party search engines, and they may use caches containing your outdated information.
3.4 Compliance with Law, Responding to Legal Requests, Preventing Harm and Protection of our Rights.
Hosting Power may disclose your information, including personal information, to courts, law enforcement or governmental authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) comply with our legal obligations, (ii) to comply with legal process and to respond to claims asserted against Hosting Power, (iii) to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability, (iv) to enforce and administer our Terms & conditions, or (v) to protect the rights, property or personal safety of Hosting Power, its employees, its Host, Students, or members of the public.
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 Hosting Power’s property.
3.5 Social Media Platforms.
Where permissible according to applicable law we may use certain limited personal information about you, such as your email address, to hash it and to share it with social media platforms, such as Facebook or Google, to generate leads, drive traffic to our websites or otherwise promote our products and services or the Hosting Power website. These processing activities are based on our legitimate interest in undertaking marketing activities to offer you products or services that may be of interest to you.
The social media platforms with which we may share your personal data are not controlled or supervised by Hosting Power. Therefore, any questions regarding how your social media platform service provider processes your personal data should be directed to such provider.
Please note that you may, at any time ask Hosting Power to cease processing your data for these direct marketing purposes by sending an e-mail with the subject title ‘Opt Out’ to email@example.com.
3.6 Business Transfers.
3.7 Aggregated Data.
We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.
4. OTHER IMPORTANT INFORMATION
4.1 Google Maps/Earth.
5. THIRD PARTY PARTNERS & INTEGRATIONS
The Hosting Power website may contain links to third party websites or services, such as third party integrations, co-branded services, or third party-branded services (“Third Party Partners”). Hosting Power doesn’t own or control these Third Party Partners and when you interact with them, you may be providing information directly to the Third Party Partner, Hosting Power, or both. These Third Party Partners will have their own rules about the collection, use, and disclosure of information. We encourage you to review the privacy policies of the other websites you visit.
6. YOUR RIGHTS
6.1 Managing Your Information.
As a Host, if you wish to update or edit any of the information on your listing, you may do so at any time by sending a request to us by email at firstname.lastname@example.org. You are responsible for keeping your personal information up-to-date.
6.2 Rectification of Inaccurate or Incomplete Information.
You have the right to ask us to correct inaccurate or incomplete personal information concerning you (and which you cannot update yourself within your Hosting Power listing).
6.3 Data Access and Portability.
In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).
6.4 Data Retention and Erasure.
We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you no longer want us to use your information to provide Hosting Power services to you, you can request that we erase your personal information and delete your Hosting Power listing. Please note that if you request the erasure of your personal information:
We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety.
We may retain and use your personal information to the extent necessary to comply with our legal obligations.
Because we maintain the Hosting Power website to protect 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.
6.5 Withdrawing Consent and Restriction of Processing.
Where you have provided your consent to the processing of your personal information by Hosting Power you may withdraw your consent at any time by sending an email to email@example.com specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing pursuant to Section 6.6 and pending the verification whether the legitimate grounds of Hosting Power override your own.
6.6 Objection to Processing.
In some jurisdictions, applicable law may entitle you to require Hosting Power not to process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing Hosting Power will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defence of legal claims.
Where your personal information is processed for direct marketing purposes, you may, at any time ask Hosting Power to cease processing your data for these direct marketing purposes by sending an e-mail with the subject title ‘Opt Out’ to firstname.lastname@example.org.
6.7 Lodging Complaints.
You have the right to lodge complaints about the data processing activities carried out by Hosting Power before the competent data protection authorities, the Irish Data Protection Commissioner.
7. GOVERNING LAW AND JURISDICTION
This Privacy Statement is governed by the laws of Ireland and is subject to the exclusive jurisdiction of the Irish courts.
We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls. If you know or have reason to believe that your Hosting Power listing credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your Hosting Power listing, please contact us by email at email@example.com.
9.1 EXCLUSION OF LIABILITY
The Data Controller and its subsidiaries, affiliates, officers, agents and employees are not liable from and against any claim, liabilities, damages, losses and/or expenses, including, without limitation, reasonable legal and accounting fees, arising out of or in any way connected with: (i) any claims made by Data Subjects; (ii) the provision of Services; and (iii) third party use of Data.
10. QUESTIONS OR COMMENTS