Our Privacy Policy explains what personal information we collect, how we use personal information, how personal information is shared, and privacy rights.
Last Updated: October 25, 2023
Airbnb TOPCC 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. As in one with Airbnb, TOPCC 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.
This Privacy Policy describes how Twin Oaks Place Condo Corp (TOPCC Corp) and its affiliates (“we,” “us,” or “TOPCC”), process personal information in relation to your use of the Twin Oaks Place. Depending on where you live and what you are doing on the Guests Airbnb TOPCC Platform, the supplemental privacy pages listed below may apply to you. Please follow the links and review the supplemental information describing how we process personal information for those regions and services.
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 the United States” 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.
If you are resident in the EEA and Switzerland, Airbnb Payments Luxembourg SA, 4 rue Henri Schnadt, L-2350 Luxembourg, is the controller of your personal information in relation to Payment Services.
Airbnb Payments UK Limited, 100 New Bridge Street, London, EC4V 6JA, United Kingdom, is the controller of your personal information if you are resident in (a) Australia, for all Payment Services except for those in connection with booking any Host Service; (b) China, for Payments Services in connection with: (i) booking or offering any Host Service, located outside your country of residence, or (ii) booking a Host Service located in your country of residence where the Host resides outside your country of residence); (c) Brazil, for Payments Services in connection with: (i) booking a Host Service, located outside of Brazil, where the Host resides outside of Brazil and paying in foreign currency, or (ii) offering any Host Service, located outside Brazil, where the Guest booking the service resides outside of Brazil and pays in foreign currency* (d) India, for Payments Services in connection with (i) booking or offering any Host Service, located outside India, or (ii) offering a Host Service in India to a Guest who resides outside of India; or (e) Japan and all other countries other than the EEA, Switzerland and United States, for Payment Services for all activities.
If you are resident in Australia, UK, the EEA and Switzerland, India, Brazil*, and all other countries outside of the United States except China and Japan, Airbnb Ireland UC, 8 Hanover Quay, Dublin 2, Ireland, is the controller of your personal information in relation to all activities other than Payment Services.
If you reside in China, Airbnb Ireland UC is the controller of your personal information in relation to booking or offering any Host Service located outside China.
If you reside in Japan, Airbnb Ireland UC is the controller of your personal information in relation to booking or offering any Host Service located outside Japan and Airbnb Global Services Limited is the controller for all other activities except for Payment Services.
*If you reside in Brazil, Airbnb Plataforma Digital Ltda is the controller of your personal information in relation to all activities, including Payment Services, from April 1, 2022.
To contact the Data Protection Officer (DPO), click here.
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 Needed to Use the Airbnb TOPCC Platform.
We collect personal information about you when you use the Airbnb TOPCC 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. 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. 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 Airbnb account settings is part of your public profile page and will be publicly visible.
Information About Others. Such as information about a co-traveler. By providing us with personal information about others, you certify that you have permission to provide that information to Airbnb TOPCC for the purposes described in this Privacy Policy and you have shared the Airbnb TOPCC Privacy Policy with them.
Other Information. Such as when you fill in a form, add information to your account, respond to surveys, post to community forums, participate in facilities reservations, communicate with Airbnb TOPCC Front Desk 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 Airbnb TOPCC Platform
When you use the Airbnb TOPCC Platform, 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.
Log Data and Device Information. Such as details about how you’ve used the Airbnb 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 Airbnb Platform. We may collect this information even if you haven’t created an Airbnb account or logged in.
Cookies and Similar Technologies As Described in Airbnb's Cookie Policy.
2.4 Personal Information We Collect from Third Parties.
We collect personal information from other sources, such as:
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.
Referrals and Co-Travelers. If you are invited to the Airbnb 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, such as references, 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 Airbnb 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
We use personal information as outlined in this Privacy Policy.
3.1 Provide, Improve, and Develop the Airbnb TOPCC Platform. We may process this information to:
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 claims or similar claims,
personalize and customize your experience based on your interactions with the Airbnb TOPCC Platform, your search and reading history, your profile information and preferences, and other content you submit, and
enable your use of our facilities accommodation services per your Host's.
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, Unit Owners 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,
comply with law, respond to legal requests, prevent harm, and protect our rights (see section 4.5),
assess or evaluate your interactions with the Airbnb Platform and information obtained from third parties. In limited cases, automated processes, which analyze your account and activities on the Airbnb platform as well as information in relation to activities on and off the Airbnb platform that can be associated with you, could restrict or suspend your access to the Airbnb Platform if such processes detect activity that may pose a safety or other risk to Airbnb, 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 incidents here.
3.3 Provide, Personalize, Measure, and Improve our Advertising and Marketing. We may process this information to:
personalize, measure, and improve our advertising,
administer referral programs, rewards, surveys, contests, or other promotional activities or events sponsored or managed by Airbnb TOPCC 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.
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 Airbnb TOPCC account or participating in promotional activities by Airbnb 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 Airbnb, 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 Member 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 Other Public Information.
You can make certain information publicly visible to others, such as:
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.
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 Airbnb TOPCC 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 Airbnb, (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 (more information on Airbnb’s Law Enforcement Guidelines here), (iv) enforce and administer our agreements with Members, including Airbnb's Terms, Additional Legal Terms, and Policies, or (v) protect the rights, property or personal safety of Airbnb, its employees, its Members, 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 or harm to Airbnb, our Members, or expose Airbnb 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 Airbnb’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 Airbnb on behalf of Guests and Hosts, to the extent any of this information is known by Airbnb.
In jurisdictions where Airbnb 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 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 Airbnb 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 Airbnb 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 Airbnb to process your data. These can include email or reservation management software. Such services are outside of Airbnb’s control and will be subject to applicable laws around the world with varying levels of data protection.
4.8 Business Transfers.
If Airbnb TOPCC undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer, or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence). In this event, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.
5. YOUR RIGHTS
You can exercise any of the rights described in this section consistent with applicable law. See here for information on data subject rights requests and how to submit a request. We may ask you to verify your identity and request before taking further action on your request.
5.1 Managing Your Information.
You can access and update some of your personal information through your Account settings. If you connected your Airbnb 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.
5.2 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).
5.3 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 Airbnb Account for fraud or safety reasons, we may retain information from that Airbnb Account to prevent that Member from opening a new Airbnb Account in the future.
We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, Airbnb and Airbnb 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 Airbnb, even after your Airbnb 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.
6. SECURITY
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.
7. CHANGES 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 revised Privacy Policy and update the “Last Updated” date at the top. In case of material changes, we will also provide you with notice of the modification by email at least thirty (30) days before the effective date. If you disagree with the revised Privacy Policy, you can cancel your Account. If you do not cancel your Account before the date the revised Privacy Policy becomes effective, your continued access to or use of the Airbnb Platform will be subject to the revised Privacy Policy.
8. CONTACT INFORMATION AND RESPONSIBLE AIRBNB TOPCC ENTITIES
For questions or complaints about this Privacy Policy or Airbnb TOPCC’s handling of personal information by emailing us at dpo@topcc.com