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Privacy Policy

Privacy Policy

INTRODUCTION

Thank you for using Express Corporate Housing! Your trust is important to us and we’re committed to protecting the privacy and security of your personal information. The information that’s shared with us helps us to provide a great experience with Express Corporate Housing. We have a dedicated privacy team that’s committed to protecting all the personal information we collect and help ensure that personal information is handled properly.

This Privacy Policy describes how we collect, use, process, and disclose your personal information, in conjunction with your access to and use of the Express Corporate Housing website and portal.

Data Controller
1. When this policy mentions “Express Corporate Housing,”, “ECH”, “we,” “us,” or “our,” it refers to Express Corporate Housing LLC, a Texas Limited Liability Corporation, that is responsible for your information under this Privacy Policy (the “Data Controller”).
How we use Information
1. We may use, store, and process personal information to (1) provide, understand, improve, and develop the ECH Platform, (2) create and maintain a trusted and safer environment (such as to comply with our legal obligations and ensure compliance with ECH Policies) and (3) provide, personalize, measure, and improve our advertising and marketing.
2. Provide, Improve, and Develop the ECH Platform.
  1. We may use the personal information to provide, improve, and develop the ECH Platform such as to:
    1. enable you to access and use the ECH Platform,
    2. enable you to communicate with other Members,
    3. operate, protect, improve, and optimize the ECH Platform and experience, such as by performing analytics and conducting research,
    4. provide customer service,
    5. send you service or support messages, updates, security alerts, and account notifications,
    6. if you provide us with your contacts’ information, we may process this information:
      1. to facilitate your referral invitations,
      2. send your requests for references,
      3. for fraud detection and prevention,
      4. for any purpose you authorize at the time of collection,
    7. to operate, protect, improve, and optimize the ECH Platform and experience, and personalize and customize your experience (such as making Listing suggestions, ranking search results), and facilitate claims with our Host Guarantee, Host Protection Insurance, Experience Protection Insurance or other similar host protection programs, we conduct profiling based on your interactions with the ECH Platform, your search and booking history, your profile information and preferences, and other content you submit to the ECH Platform, and enable your use of our enterprise products.
  2. We process this personal information for these purposes given our legitimate interest in improving the ECH Platform and our Members’ experience with it, and where it is necessary for the adequate performance of the contract with you.
3. Create and Maintain a Trusted and Safer Environment. We may use the personal information to create and maintain a trusted and safer environment such as to:
  1. detect and prevent fraud, spam, abuse, security incidents, and other harmful activity,
  2. conduct security investigations and risk assessments,
  3. verify or authenticate information or identifications provided by you,
  4. 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,
  5. comply with our legal obligations,
  6. Resolve any disputes with any of our Members and enforce our agreements with third parties,
  7. enforce our Terms of Service and other policies, and
  8. in connection with the activities above, we may conduct profiling based on your interactions with the ECH Platform, your profile information and other content you submit to the ECH Platform, and information obtained from third parties. In limited cases, automated processes may restrict or suspend access to the ECH Platform if such processes detect activity that we think poses a safety or other risk to the ECH Platform, our community, or third parties. If you challenge the decisioning based on the automated process, please contact us as provided in the Contact Us section below.
  9. We process this personal information for these purposes given our legitimate interest in protecting the ECH Platform, to measure the adequate performance of our contract with you, and to comply with applicable laws.
4. Provide, Personalize, Measure, and Improve our Advertising and Marketing. We may use the personal information to provide, personalize, measure, and improve our advertising and marketing such as to:
  1. send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences (including information about ECH or partner campaigns and services) and social media advertising through social media platforms such as Facebook or Google),
  2. personalize, measure, and improve our advertising,
  3. Administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by ECH or its third party partners,
  4. conduct profiling on your characteristics and preferences (based on the information you provide to us, your interactions with the ECH Platform, information obtained from third parties, and your search and booking history) to send you promotional messages, marketing, advertising and other information that we think may be of interest to you,
  5. enrolling in an email subscription will not affect the frequency of administrative emails that we may send in connection with any ECH Account. No fee is charged for sending promotional emails to you, but third-party data rates may apply. Note that you may not be able to take advantage of certain promotions if you do not have an ECH Account, and
  6. invite you to events and relevant opportunities.
  7. 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 your interest.
5. How the Data Controller uses the Personal Information Collected for payments. We may use the personal information as a part of payment services such as to:
  1. Enable you to access and use the payment services.
  2. Detect and prevent fraud, abuse, security incidents, and other harmful activity.
  3. Conduct security investigations and risk assessments.
  4. Conduct background checks, checks against databases and other information sources.
  5. Comply with legal obligations (such as anti-money laundering regulations).
  6. Enforce the Payment Terms and other payment policies.
  7. With your consent, send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences.
  8. The Data Controller processes this personal 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.
Identity Verification Information.
1. To help create and maintain a trusted environment, we may collect 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.
Sharing Information with Third Parties
1. General
  1. To operate our business, we share Information with third-party companies to perform legitimate business functions. Functions include renting apartments, performing background checks, performing credit checks, analyzing website performance, purchasing utilities, shredding documents, and insuring units. These third parties are given only the Information necessary to perform their job. By using our website and services, you consent to your information being shared with our partners.
  2. We do not sell personal information to third party marketing companies or data aggregation companies. We do allow third parties to collect personal information through our Service and share personal information with third parties for the business purposes described in this Privacy Policy, including without limitation advertising and marketing on our Service and elsewhere based on users’ online activities over time and across different sites, services, and devices.
2. Property Managers and Owners.
  1. We may share personal information and booking information with landlords, management companies, and/or property owners in order to facilitate programs with these partners. For example, guest booking and personal information may be shared with owners and property managers of the building, complex, or planned community where a host lives and/or the listing is to facilitate hosting services, security, billing, and other services that may be provided.
3. Guest Information Provided to ECH for Enterprise Customers.
  1. If you have linked your account with an Enterprise(your employer or company’s account), and you are included on a booking designated as being for business purposes, we may disclose information related to the booking to the Enterprise to the extent necessary for the adequate performance of ECH’s contract with the Enterprise. Typically, this includes information related to the booking, such as your name, dates of the booking, number of guests, pricing, Listing details, the Accommodation address, and other related information. At the request of you or your Enterprise, we may also disclose this information to service providers engaged by it, such as companies that provide travel management, financial reporting, personnel management, crisis management, or other services. In the event of a dispute, emergency, or similar situation involving a booking identified as being for business purposes, ECH may also share additional relevant information it believes is necessary to safely and quickly address the situation.
4. Service Providers.
  1. ECH uses a variety of third-party service providers to help us provide services related to the ECH Platform. Service providers may be located inside or outside of the European Economic Area (“EEA”).
  2. For example, service providers may help us: (i) verify your identity or authenticate your identification documents, (ii) check information against public databases, (iii) conduct background or police checks, fraud prevention, and risk assessment, (iv) perform product development, maintenance and debugging, (v) allow the provision of ECH services through third party platforms and software tools (e.g. through the integration with our APIs), (vi) provide customer service, advertising, or payments services, or (vii) process, handle or assess insurance claims or other similar claims. These providers have limited access to your personal information to perform these tasks on our behalf, and are contractually bound to protect the personal information and only use the personal information in accordance with our instructions.
  3. ECH will need to share your information, including personal information, in order to ensure the adequate performance of our contract with you.
Corporate Affiliates. To enable or support us in providing the ECH Platform, we may share your information, including personal information, within our corporate family of companies (both financial and non-financial entities) that are related by common ownership or control.
1. Sharing with Express Corporate Housing, LLC.
  1. Even if your country of residence is not the United States, your information may be shared with Express Corporate Housing, LLC. which provides the technical infrastructure for the ECH Platform, product development and maintenance, customer support, trust and safety and other business operation services to other ECH entities. The data sharing is necessary for the performance of the contract between you and us and is based on our legitimate interests in providing the ECH Platform globally.
2. Sharing with GoRoverGo (a division of Express Corporate Housing).
  1. In order to facilitate fulfillment of services and process payments through the ECH platform; certain information may be shared with GoRoverGo (a division of Express Corporate Housing). The data sharing is necessary for the performance of the contract between you and us.
Aggregate Data
1. We may use or share aggregated, anonymized data. This is Information that is no longer connected to an individual user and cannot be used to identify any user.
Children’s Data.
1. Our websites and applications are not directed to children under 18 and we do not knowingly collect any personal information directly from children under 18. If you believe that we are processing the personal information pertaining to a child inappropriately, we take this very seriously and urge you to contact us using the information provided under the “Contact Us” section below.
Compliance with Law, Responding to Legal Requests, Preventing Harm and Protection of our Rights.
1. ECH may disclose your information, including personal information, to courts, law enforcement, governmental authorities, tax 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) to comply with our legal obligations, (ii) to comply with a valid legal request or to respond to claims asserted against ECH, (iii) to respond to a valid legal request 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 of Service, the Payment Terms or other agreements with Members, or (v) to protect the rights, property or personal safety of ECH, its employees, its Members, or members of the public.
2. These disclosures may be necessary to comply with our legal obligations, for the protection of your or another person's vital interests or for the purposes of our or a third party’s legitimate interest in keeping the ECH Platform secure, preventing harm or crime, enforcing or defending legal rights, facilitating the collection of taxes and prevention of tax fraud or preventing damage.
3. 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 ECH’s property, its Members and the ECH Platform. In instances where we comply with legal requests without notice for these reasons, we may attempt to notify that Member about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.
Rights to Your Data in the European Union
1. Under the GDPR, users in the European Union have the following rights regarding Information we’ve collected from them:
  1. Users can access Information
  2. Users can make corrections to Information
  3. Users can object to data processing
  4. Users can request their Information is erased
  5. Users can withdraw consent to GDPR Chapter 3
2. Please note that if a user objects to us processing their data, we will be unable to provide services to that user.
California & Vermont Residents.
1. ECH will not share information it collects about you with its affiliates or third parties (both financial and non-financial), except as required or permitted by your state’s law.
California Privacy Rights.
1. California law permits Members who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those third parties. See the “Contact Us” section for where to send such requests. ECH does not share personal information with third parties for their own direct marketing purposes without your prior consent. Accordingly, you can prevent disclosure of your personal information to third parties for their direct marketing purposes by withholding consent.
2. Effective January 1, 2020, the California Consumer Privacy Act (CCPA) allows California residents, upon a verifiable consumer request, to request that a business that collects consumers’ personal information to give consumers access, in a portable and (if technically feasible) readily usable form, to the specific pieces and categories of personal information that the business has collected about the consumer, the categories of sources for that information, the business or commercial purposes for collecting the information, and the categories of third parties with which the information was shared. California residents also have the right to submit a request for deletion of information under certain circumstances. Consistent with California law, if you choose to exercise your rights, we won’t charge you different prices or provide different quality of services unless those differences are related to your information. Please note that you must verify your identity and request before further action is taken. As a part of this process, government identification may be required. Consistent with California law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government issued identification, and the authorized agent’s valid government issued identification.
OTHER IMPORTANT INFORMATION
1. Analyzing your Communications.
  1. We may review, scan, or analyze your communications on the ECH Platform for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, analytics, and customer support purposes. For example, as part of our fraud prevention efforts, we scan and analyze messages to mask contact information and references to other websites. In some cases, we may also scan, review, or analyze messages to debug, improve, and expand product offerings. We use automated methods where reasonably possible. However, occasionally we may need to manually review some communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools. We will not review, scan, or analyze your messaging communications to send third party marketing messages to you, and we will not sell reviews or analyses of these communications. These activities are carried out based on ECH's legitimate interest in ensuring compliance with applicable laws and our Terms, preventing fraud, promoting safety, and improving and ensuring the adequate performance of our services.
YOUR RIGHTS: Consistent with applicable law, you may exercise any of the rights described in this section before your applicable Data Controller. Please note that we may ask you to verify your identity and request before taking further action on your request.
1. Managing Your Information.
  1. You may access and update some of your information through your Account settings. You are responsible for keeping your personal information up to date.
2. Rectification of Inaccurate or Incomplete Information.
  1. You have the right to ask us to correct inaccurate or incomplete personal information about you which you cannot update yourself within your ECH Account.
3. Data Access and Portability.
  1. In some jurisdictions, applicable law may entitle you to request certain 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).
4. Data Retention and Erasure.
  1. 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. In certain jurisdictions, you can request to have all your personal information deleted entirely." Please note that if you request the erasure of your personal information:
    1. We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend an ECH Account for fraud or safety reasons, we may retain certain information from that ECH Account to prevent that Member from opening a new ECH Account in the future.
    2. We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, ECH may keep some of your information for tax, legal reporting and auditing obligations.
    3. Information you have shared with others (e.g., Reviews, forum postings) may continue to be publicly visible on the ECH Platform, even after your ECH Account is cancelled. However, attribution of such information to you will be removed. Additionally, some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers.
    4. Because we maintain the ECH Platform 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.
5. Withdrawing Consent and Restriction of Processing.
  1. If we are processing your personal information based on your consent you may withdraw your consent at any time by changing your Account settings or by sending a communication to ECH 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 defense 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 ECH override your own.
6. Objection to Processing.
  1. In some jurisdictions, applicable law may entitle you to require ECH 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 ECH 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 defense of legal claims.
  2. Where your personal information is processed for direct marketing purposes, you may, at any time ask ECH to cease processing your data for these direct marketing purposes by sending an e-mail to the Data Controller.
7. Lodging Complaints.
  1. You have the right to lodge complaints about our data processing activities by filing a complaint with our Data Protection Officer who can be reached by the “Contact Us” section below or with a supervisory authority.
Business Transfers.
1. If ECH 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.
Information We Automatically Collect from Your Use of the ECH Platform.
1. When you use the ECH Platform, we automatically collect 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 ECH Platform.
  1. Geo-location Information. When you use certain features of the ECH Platform, we may collect information about your precise or approximate location as determined through data such as your IP address or mobile device’s GPS to offer you an improved user experience. Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings menu. ECH may also collect this information even when you are not using the app if this connection is enabled through your settings or device permissions.
  2. Usage Information. We collect information about your interactions with the ECH Platform such as the pages or content you view, your searches for Listings, bookings you have made, and other actions on the ECH Platform.
  3. Log Data and Device Information. We automatically collect log data and device information when you access and use the ECH Platform, even if you have not created an ECH Account or logged in. That information includes, among other things: details about how you’ve used the ECH 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, cookie data, and the pages you’ve viewed or engaged with before or after using the ECH Platform.
  4. Cookies and Similar Technologies. We use cookies and other similar technologies when you use our platform, use our mobile app, or engage with our online ads or email communications. We may collect certain information by automated means using technologies such as cookies, web beacons, pixels, browser analysis tools, server logs, and mobile identifiers. In many cases the information we collect using cookies and other tools is only used in a non-identifiable without reference to personal information. For example, we may use information we collect to better understand website traffic patterns and to optimize our website experience. In some cases we associate the information we collect using cookies and other technology with your personal information. Our business partners may also use these tracking technologies on the ECH Platform or engage others to track your behavior on our behalf. Disabling cookies may prevent users from accessing or using certain features on our website or using our services.
  5. Pixels and SDKs. Third parties, including Facebook, may use cookies, web beacons, and other storage technologies to collect or receive information from our websites and elsewhere on the internet and use that information to provide measurement services and target ads. For apps, that third parties, including Facebook, may collect or receive information from your app and other apps and use that information to provide measurement services and targeted ads. Users can opt-out of the collection and use of information for ad targeting by updating their Facebook account ad settings and by contacting opt-out@expresscorporatehousing.com with a description of your request and validation information. Users can access a mechanism for exercising such choice by going to http://www.aboutads.info/choices and http://www.youronlinechoices.eu/.
  6. Do Not Track Signals. While you may disable the usage of cookies through your browser settings, the ECH Platform currently does not respond to a “Do Not Track” signal in the HTTP header from your browser or mobile application due to lack of standardization regarding how that signal should be interpreted.
  7. Payment Transaction Information. ECH collects information related to your payment transactions through the ECH Platform, 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 ECH and to allow the provision of the payment services.
SMS Terms for U.S.
1. For text messaging in the United States, by requesting, joining, agreeing to, enrolling in, signing up for, acknowledging, or otherwise consenting to receive one or more text messages (“Opting In”) or using a ECH arrangement in which ECH sends (or indicates that it may send, or receives a request that it send) one or more text messages (“Text Message Service”), you accept these SMS Terms for U.S. (“SMS Terms”), consent to the handling of your personal information as described in the ECH Privacy Policy, and agree to resolve disputes with ECH as described in our Terms of Service. Message and data rates may apply.
2. ECH will use reasonable commercial efforts to deliver the automated marketing text messages to the number you provide through compatible wireless carriers. Carriers and ECH are not liable for delayed or undelivered messages. The short code we use for some Text Message Services may not be supported on all U.S. carriers.
3. Opting In - By Opting In to a Text Message Service:
  1. You expressly authorize ECH to use autodialer or non-autodialer technology to send text messages to the cell phone number associated with your Opt-In (i.e., the number listed on the Opt-In form or instructions, or, if none, the number from which you send the Opt-In, or, if none, the number on file for your account). You also authorize ECH to include marketing content in any such messages. You do not have to Opt In or agree to Opt In as a condition of purchase.
  2. You consent to the use of an electronic record to document your Opt-In. To withdraw that consent, request a free paper or email copy of the Opt-In, or to update our records with your contact information, please contact us via the methods described in the Contact Us section. To view and retain an electronic copy of these SMS Terms or the rest of your Opt-In, you will need (i) a device (such as a computer or cell phone) with internet access, and (ii) either a printer or storage space on such device. If you withdraw your consent, certain features of our service may not be available to you. To update information on how we would contact you electronically, visit your Notification settings in your account settings.
  3. You confirm that you are the subscriber to the relevant phone number or that you are the customary user of that number on a family or business plan and that you are authorized to Opt In.
  4. You consent to the use of an electronic record to document your Opt-In. To withdraw that consent, update our records with your contact information, please visit your ECH account Notifications settings or contact customer support.
4. These SMS Terms still will apply if you withdraw the consent mentioned above or opt out of the Text Message Service.
5. After Opting In, in addition to the main messages the service offers, you may receive one or more welcome messages or administrative messages, such as (in some cases) a request to confirm your Opt-In.
6. About the Text Message Services and Opting Out
  1. Message and data rates may apply. Unless otherwise noted, Text Message Services send multiple, recurring messages. ECH may terminate any Text Message Service or your participation in it at any time with or without notice, including, for example, before you have received any or all messages that you otherwise would have received, but these SMS Terms still will apply. Text STOP to any promotional message to Opt Out or if applicable update your “Notification” settings on your ECH account.
7. For additional help, text HELP in response to a marketing message or contact customer service.
SECURITY
1. 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 ECH Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your ECH Account, please contact us following the instructions in the Contact Us section below.
CHANGES TO THIS PRIVACY POLICY
1. ECH reserves the right to modify this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on the ECH Platform and update the “Last Updated” date at the top of this Privacy Policy. We will also provide you with notice of the modification by email at least thirty (30) days before the date they become effective. If you disagree with the revised Privacy Policy, you may 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 ECH Platform will be subject to the revised Privacy Policy.
CONTACT US
1. If you have any questions or complaints about this Privacy Policy or ECH’s information handling practices, you may email us at the email addresses provided in the relevant sections above or contact us via mail at:

Privacy Management
Express Corporate Housing
12777 Jones RD STE 450
Houston, TX 77070

privacy@expresscorporatehousing.com