Information about Fretish

Privacy Policy

Last updated: May 24, 2018

Thank you for using Fretish!

This Privacy Policy explains how we collect, use, process, and disclose your information across the Fretish Platform.

If you see an undefined term in this Privacy Policy (such as “Listing” or “Fretish Platform”), it has the same definition as outlined in our Terms of Service.

When this policy mentions “Fretish,” “we,” “us,” or “our,” it refers to the Fretish company that is responsible for your information under this Privacy Policy (the “Data Controller”).

If you reside in the United States, the Data Controller is Austin Siena, LLC (dba Fretish)

This Privacy Policy also applies to the Payment Services provided to you by Fretish Payments pursuant to the Payments Terms of Service (“Payments Terms”). 

1. INFORMATION WE COLLECT

There are three general categories of information we collect.

1.1 Information You Give Us.

We collect information you share with us when you use the Fretish Platform.

Account Information. When you sign up for an Fretish Account, we require certain information such as your name, email address, and date of birth.
Profile Information. To use certain features within the Fretish Platform, we may also ask you to complete a profile, which may include your address, phone number, and gender. Certain parts of your profile (like your profile picture, first name, and description) are a part of your public profile page, and will be publicly visible to others.
Other Authentication-Related Information. To help create and maintain a trusted environment, we may collect identification (like a photo of your government-issued ID) or other authentication information. To learn more, see our Help Center article about providing identification on Fretish.
Payment Information. We collect your financial information (like your bank account or credit card information) when you use the Payment Services to process payments.
Communications with Fretish and other Members. When you communicate with Fretish or use the Fretish Platform to communicate with other Members, we collect information about your communication and any information you choose to provide.
Address Book Contact Information. You may choose to import your address book contacts or enter your contacts’ information manually to access certain features of the Fretish Platform, like inviting them to use Fretish.
Other Information. You may otherwise choose to provide us information when you fill in a form, conduct a search, update or add information to your Fretish Account, respond to surveys, post to community forums, participate in promotions, or use other features of the Fretish Platform.

1.2 Information We Automatically Collect from Your Use of the Fretish Platform.

When you use the Fretish Platform, we collect information about the services you use and how you use them.

Usage Information. We collect information about your interactions with the Fretish Platform, such as the pages or other content you view, your searches for Listings, bookings you have made, and other actions on the Fretish Platform.
Location Information. When you use certain features of the Fretish Platform, we may collect different types of information about your general location (e.g. IP address, zip code) or more specific location information (e.g. precise location from your mobile GPS). Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings menu.
Log Data. We automatically collect log information when you use the Fretish Platform, even if you have not created an Fretish Account or logged in. That information includes, among other things: details about how you’ve used the Fretish Platform (including links to third party applications), IP address, access times, hardware and software information, device information, device event information (e.g., crashes, browser type), and the page you’ve viewed or engaged with before or after using the Fretish Platform.
Transaction Information. We collect information related to your transactions on the Fretish Platform, including the date and time, amounts charged, and other related transaction details.
Cookies and Similar Technologies. We use cookies and other similar technologies, such as web beacons, pixels, and mobile identifiers. We may also allow our business partners to use these tracking technologies on the Fretish Platform, or engage others to track your behavior on our behalf. While you may disable the usage of cookies through your browser settings, we do not change our practices in response to a “Do Not Track” signal in the HTTP header from your browser or mobile application. For more information on our use of these technologies, see our Cookie Policy.

1.3 Information We Collect from Third Parties.

We may collect information that others provide about you when they use the Fretish Platform, or obtain information from other sources and combine that with information we collect through the Fretish Platform.

Third Party Services. If you link, connect, or login to your Fretish Account with a third party service (e.g., Facebook, WeChat), 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.
Your References. If someone has written a reference for you, it will be published on your Fretish public profile page. To learn more about how this works, see our Help Center article about References.
Background Information. For Members in the United States, to the extent permitted by applicable laws, Fretish may obtain reports from public records of criminal convictions or sex offender registrations. For Members outside of the United States, to the extent permitted by applicable laws, Fretish may obtain the local version of background or registered sex offender checks. We may use your information, including your full name and date of birth, to obtain such reports.
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 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 Fretish Platform through partnerships, or about your experiences and interactions from our partner ad networks.

2. HOW WE USE INFORMATION WE COLLECT

We use, store, and process information about you to provide, understand, improve, and develop the Fretish Platform, and to create and maintain a trusted and safer environment.

2.1 Provide, Improve, and Develop the Fretish Platform.

Enable you to access and use the Fretish Platform.
Enable you to communicate with other Members.
Operate, protect, improve and optimize the Fretish Platform and experience, such as by performing analytics and conducting research.
Personalize or otherwise customize your experience by, among other things, ranking search results or showing ads based on your search, booking history, and preferences.
Enable you to access and use the Payment Services.
Provide customer service.
Send you service or support messages, such as updates, security alerts, and account notifications.
If you provide us with your contacts’ information, we may use and store this information: (i) to facilitate your referral invitations, (ii) send your requests for references, (iii) for fraud detection and prevention, and (iv) for any purpose you authorize at the time of collection.

2.2 Create and Maintain a Trusted and Safer Environment.

Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity.
Conduct investigations and risk assessments.
Verify or authenticate information or identifications provided by you (such as to verify your Equipment address or compare your identification photo to another photo you provide).
Conduct checks against databases and other information sources.
Comply with our legal obligations.
Resolve any disputes with any of our users and enforce our agreements with third parties.
Enforce our Terms of Service, Payments Terms, and other policies.

2.3 Provide, Personalize, 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 communication preferences (including information about Fretish or partner campaigns and services).
Personalize, measure, and improve advertising.
Administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Fretish or its third party business partners.

3. SHARING & DISCLOSURE

3.1 With Your Consent.

We may share your information at your direction or as described at the time of sharing, such as when you authorize a third party application or website to access your Fretish Account.

3.2 Sharing between Owners, Renters and Co-Owners.

To help facilitate bookings, we may share your information with other Members as follows:

When you as a Renter submit a booking request, certain information about you is shared with the Owner (and Co-Owner, if applicable), including your full name, the full name of any additional Renters, your cancellation history, and other information you agree to share. When your booking is confirmed, we will disclose additional information to assist with coordinating the trip, like your phone number.
When you as a Owner (or Co-Owner, if applicable) have a confirmed booking, certain information is shared with the Renter to coordinate the booking, such as your full name, phone number, and Equipment or Experience address.
When you as a Owner invite another Member to become a Co-Owner, you authorize the Co-Owner to access your information and Member Content, including but not limited to certain information like your full name, phone number, Equipment address, and email address.
We don’t share your billing and payout information with other Members.

3.3 Profiles, Listings, and other Public Information.

The Fretish Platform lets you publish information that is visible to the general public. For example:

Parts of your public profile page, such as your first name, your description, and city, are publicly visible to others.
Public Listing pages are publicly visible and include information such as the Equipment or Experience’s approximate location (neighborhood and city), Listing description, calendar availability, the Owner public profile photo, aggregated demand information (like page views over a period of time), and any additional information the Owner chooses to share.
After completing a booking, Renters and Owners may write reviews and rate each other. Reviews are a part of your public profile page.
If you submit content in a public forum or social media post, or use a similar feature on the Fretish Platform, that content is publicly visible.
Information you share publicly on the Fretish Platform may be indexed through third party search engines. In some cases, you may opt-out of this feature in your Account settings. If you change your settings or your public-facing content, these search engines may not update their databases. We do not control the practices of third party search engines, and they may use caches containing your outdated information.

3.4 Service Providers.

We use a variety of third party service providers to help us provide services related to the Fretish Platform. Service providers may be located inside or outside of the European Economic Area (“EEA”). For example, service providers may help us: (i) verify or authenticate your identification, (ii) check information against public databases, (iii) assist us with background checks, fraud prevention, and risk assessment, or (iv) provide customer service, advertising, or payments services. These providers have limited access to your information to perform these tasks on our behalf, and are contractually obligated to use it consistent with this Privacy Policy.

3.5 Additional Services by Owners.

Owners may use third party services available through the Fretish Platform to assist with managing their Equipment or providing additional services, such as cleaning services or lock providers. Owners may use features on the Fretish Platform to share information about the Renter (like check-in and check-out dates, Renter name, Renter phone number, and Renter anonymized email address) with that third party service provider for the purposes of coordinating the stay, managing the Equipment, or delivering other services.

3.6 Fretish Payments.

Fretish Payments may share your personal information to: (i) provide the Payment Services, (ii) facilitate your use of the Fretish Platform, and (iii) jointly market products or services to you with other financial third parties with whom Fretish Payments has a formal agreement. You can unsubscribe or opt-out from receiving such marketing communications in your Account settings.

3.7 Safety and Compliance with Law.

Fretish may disclose your information to courts, law enforcement or governmental authorities, or authorized third parties, if and to the extent we are required to do so by law or if such disclosure is reasonably necessary: (i) to comply with legal process and to respond to claims asserted against Fretish, (ii) 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, (iii) to enforce and administer our Terms of Service or other agreements with Members, (iv) for fraud investigation and prevention, risk assessment, customer support, product development and debugging purposes, or (v) to protect the rights, property or personal safety of Fretish, its employees, its Members, or members of the public.

We will attempt to notify Members about these 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 Fretish’s property, its Members and the Platform (collectively, “Risk Scenarios”). In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that Member about the request after the fact if we determine in good faith that we are no longer legally prohibited from doing so and that no Risk Scenarios apply.

3.8 Corporate Affiliates.

To help us provide the Fretish Platform, we may share your information within our corporate family of companies (both financial and non-financial entities) that are related by common ownership or control. These related entities are covered under this Privacy Policy, and when services have additional terms specific to them, we tell you through the Fretish Platform.

Sharing with Fretish Ireland. If you reside in the United States, some of your information may be shared with Fretish Ireland when you create a Listing or when you book a Owner Service located outside of the United States (other than in China). The information shared in these circumstances may include: (i) your name, e-mail address and phone number, (ii) information relating to the Listing or Owner Service, including its address, (iii) booking information for the Listing or Owner Service, including but not limited to booking dates and payment amounts, and (iv) the names, nationalities, and identification details (including passport/national ID numbers and expiry dates) of any Renters. Additionally, when you send a message to a Owner or Renter outside of the United States (other than China), your first name, profile picture and message content sent via the Fretish Platform will be shared with Fretish Ireland.
Sharing with Fretish China. Even if you don’t reside in China, some of your information will be shared with Fretish China in the following circumstances:
Creating a Listing. If you create a Listing in China: (i) your name and phone number, (ii) information relating to the Listing (e.g., address), (iii) booking information relating to the Listing, such as Renter details as set out below in Owner Services, booking dates, and payment amounts, and (iv) messages between you and prospective and confirmed Renters at the Listing.
Owner Services. If you book a Owner Service located in China: (i) your name and phone number, (ii) booking dates, (iii) messages between the Owner and you or other Renters on the same booking, and (iv) the names, nationalities, and identification details (including passport/national ID numbers and expiry dates) of any Renters.
Sending Messages. If you send a message to a Owner in relation to that Owner’s Listing in China, your first name, profile picture and message content.
We’ll notify you in advance in the above situations, and in specific situations where we apply any practices for China that differ from what is described in this Privacy Policy (including practices pertaining to disclosures to Chinese government agencies).

3.9 Widgets.

We may display parts of the Fretish Platform (e.g., your Listing page) on sites operated by Fretish’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.

3.10 Tax Authorities.

In jurisdictions where we facilitate the Collection and Remittance of Instrument Rental Taxes as described in the “Taxes” section of the Terms of Service, Owners and Renters expressly grant us permission, without further notice, to disclose Owners’ and Renters’ data and other information relating to them or to their transactions, bookings, Equipments and Instrument Rental Taxes to the relevant tax authority, including, but not limited to, the Owner or Renter’s name, listing addresses, transaction dates and amounts, tax identification number(s), the amount of taxes received (or due) by Owners from Renters, and contact information.

3.11 Owner Information Provided to Business Travel Program Customers.

If a booking is designated as being for business purposes and made by a Renter affiliated with a company or other organization enrolled in our Business Travel Program (either or both an “Enterprise”), we may disclose information related to the booking to the Enterprise, such as the name of the Owner, the Equipment address, pricing, Listing details, and other related information. At the request of the Enterprise, we may also share this information with third parties engaged by it to provide travel management, financial reporting, personnel management, crisis management, or other services.

3.12 Renter Information Provided to Business Travel Program Customers.

If you have linked your Fretish Account with an Enterprise, and you are included on a booking designated as being for business purposes, we may disclose information related to the booking to your Enterprise. Typically, this includes your name, dates of the booking, number of Renters, pricing, Listing details, the Equipment pick up/drop off address, and other related information. At the request of 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, Fretish may also share relevant information it believes is necessary to safely and quickly address the situation.

3.13 Business Transfers.

If Fretish 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 this event, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.

3.14 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 non-personally identifiable information for industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.

4. OTHER IMPORTANT INFORMATION

4.1 Analyzing your Communications.

We may review, scan, or analyze your communications on the Fretish Platform for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, 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 communications to send third party marketing messages to you, and we will not sell reviews or analyses of these communications.

4.2 Linking Third Party Accounts.

You may link your Fretish Account with your account at a third party social networking service. Your contacts on these third party services are referred to as “Friends.” When you create this link:

some of the information you provide to us from the linking of your accounts may be published on your Fretish Account profile;
your activities on the Fretish Platform may be displayed to your Friends on the Fretish Platform and/or that third party site;
a link to your public profile on that third party social networking service may be included in your Fretish public profile;
other Fretish users may be able to see any common Friends that you may have with them, or that you are a Friend of their Friend if applicable;
other Fretish users may be able to see any schools, hometowns or other groups you have in common with them as listed on your linked social networking service;
the information you provide to us from the linking of your accounts may be stored, processed and transmitted for fraud prevention and risk assessment purposes; and
the publication and display of information that you provide to Fretish through this linkage is subject to your settings and authorizations on the Fretish Platform and the third party site.

4.3 Google Maps/Earth.

Parts of the Fretish Platform use Google Maps/Earth services, including the Google Maps API(s). Use of Google Maps/Earth is subject to Google Maps/Earth Additional Terms of Use and the Google Privacy Policy.

5. THIRD PARTY PARTNERS & INTEGRATIONS

The Fretish Platform 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”). Fretish 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, Fretish, 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 CHOICES

6.1 Access and Update.

You may review, update, or delete the information in your Fretish Account by logging into your Fretish Account and reviewing your Account settings and profile.

6.2 Account Cancellation.

For information on how to cancel your Fretish Account, visit www.Fretish.com/help. Note that information that you have shared with others (like Reviews or forum postings) may continue to be publicly visible on the Fretish Platform in association with your first name, even after your Fretish Account is cancelled.

6.3 EU and Japan Residents: Review and Update Your Information.

If you reside in the EU or Japan, you may request in writing copies of your personal information held by us. We will provide you with a copy of the personal information held by us as soon as practicable, and in any event not more than 40 days after receiving a valid request in writing. There may be a charge to access your personal data (which will not exceed €6.35 in Ireland and £10 in the United Kingdom, and will not be applicable in Japan). We may request proof of identification to verify your access request.

If your personal information that we hold is inaccurate, let us know and we will update the relevant information. You may also request the erasure of your personal information in accordance with the relevant data protection legislation. We will notify you within 40 days of your valid request about the relevant action taken.


6.4 EU Residents: Access and Challenge Information Provided to Us By Third Parties.

You are entitled to see and challenge information third parties provide to us as part of our fraud detection, prevention and risk assessment efforts if all of the following factors apply: (i) we use third parties to carry out automated checks or risk assessments, (ii) we make a decision which has legal consequences for you or which significantly affects you, and (iii) such decision is based solely on such automated checks or risk assessments.

We may request proof of identification to verify your request.

7. OPERATING GLOBALLY

As described in this Privacy Policy, we may sometimes share your information within our family of companies or with third parties. When you use the Fretish Platform, you authorize us to transfer, store, and process your information in the United States and possibly other countries. Laws in these countries may differ from the laws applicable to the place where you live. For example, information collected within the EEA may be transferred, stored, and processed outside of the EEA for the purposes described in this Privacy Policy. By using the Fretish Platform, you consent to transferring your data to these countries.

7.1 EU-US & Swiss-US Privacy Shield.

Fretish complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, respectively. Fretish has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more, see Fretish’s Privacy Shield certification.

Under the Privacy Shield Framework, Fretish is subject to the authority of the Federal Trade Commission. If you have any questions or concerns relating to our Privacy Shield certification, contact us at Austin Siena, LLC (dba Fretish), Boston, MA 02116 or via email. If we are not able to resolve your concern, you may also contact your European Data Protection Authority or Commissioner or seek assistance from our designated Privacy Shield independent recourse mechanism, JAMS. In certain circumstances, you may also have the right to pursue binding arbitration through the Privacy Shield Framework, as described in Annex I to the Privacy Shield Principles.

As explained in this Privacy Policy, we sometimes share information with third parties to perform services on our behalf. Fretish remains responsible for information that is shared under the Privacy Shield with these third parties, except where we can establish that Fretish was not responsible for the violation.

7.2 California & Vermont Residents.

Fretish Payments will not share information it collects about you with their affiliates or third parties (both financial and non-financial), except as required or permitted by your state’s law.

8. SECURITY

We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. However, the Internet is not a 100% secure environment so we can’t guarantee the security of the transmission or storage of your information.

9. CHANGES TO THIS PRIVACY POLICY

Fretish 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 Fretish 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 or use of the Fretish Platform will constitute acceptance of the revised Privacy Policy.

10. CONTACT

If you have any questions or complaints about this Privacy Policy or Fretish’s information handling practices, you may contact us at:

For residents of the United States: Austin Siena LLC (dba Fretish), Boston, MA 02116.
For residents outside of the United States: You may email us.

Privacy Policy
Last Updated: July 2, 2017


Fretish PRIVACY POLICY
Fretish (hereinafter referred to as “Fretish”, “we”, “us” or “our”) operates a platform and community marketplace that helps people form offline experiences and relationships directly with one another, where they can create, list, discover and book unique Equipments around the world, whether through our website or our mobile applications (“Platform”).

Fretish refers to (i) Fretish, Inc. if you reside in the USA, (ii) Fretish Ireland UC (hereinafter referred to as Fretish Ireland) if you reside outside of the USA and the People’s Republic of China (which for purposes of this Privacy Policy does not include Hong Kong, Macau and Taiwan) (hereinafter “China”), and (iii) Fretish Internet (Beijing) Co., Ltd. (“Fretish China”) if you reside in China, except where you book an Equipment or create a Listing outside of China, in which case, Fretish refers to Fretish Ireland for that transaction. Fretish Payments, Inc. is a subsidiary of Fretish, Inc. that processes payments for Renters and Owners that use a Payment Method or Payout Method issued in the USA; Fretish China similarly handles such payments for Renters and Owners that use a Payment Method or Payout Method issued in China; Fretish Payments India Pvt. Ltd. similarly handles such payments for Renters and Owners that use a Payment Method or Payout Method issued in India; and Fretish Payments UK Ltd. similarly handles such payments for Renters and Owners that use a Payment Method or Payout Method issued outside of the USA, China and India. Fretish Payments, Inc., Fretish Payments UK Ltd., Fretish China, and Fretish Payments India Pvt. Ltd. (collectively, “Fretish Payments”) are responsible for processing your Personal Information in connection with Payments Services related to use of the Fretish Site, Application and Services. Additionally, if your Fretish contracting entity under this Section is Fretish China, you will nevertheless contract with Fretish Ireland and Fretish Payments UK Ltd. for all Bookings confirmed prior to December 7, 2016 at 10:00am UTC.

This Privacy Policy is intended to inform you about how we treat Personal Information that we process about you. If you do not agree to any part of this Privacy Policy, then we cannot provide the Platform or Services to you, and you should stop accessing the Platform and deactivate your Fretish Account. You can find out more about how to deactivate your Fretish Account at www.Fretish.com/help.


DEFINITIONS
Where the definition of a term does not appear in this Privacy Policy (such as “Listing”, “Equipment”, “Content,” “Services” etc.), it shall be given its definition as outlined in our our Terms of Service.

“Affiliates” means companies related by common ownership or control. They can be financial and non-financial companies.

“Aggregated Information” means information about all of our users or specific groups or categories of users that we combine together so that it no longer identifies or references an individual user.

“Data Controller” means Fretish, the company responsible for the use and processing of Personal Information.

“Third Parties” means companies or persons not related by common ownership or control (i.e. non-affiliates) or other unrelated individuals. Third Parties can be financial and non-financial companies, or persons other than you and Fretish.

“Personal Information” means information (which may include sensitive information) relating to a living individual who is or can be identified either from that information or from that information in conjunction with other information that is in, or is likely to come into, the possession of the Data Controller.


WHAT TYPES OF INFORMATION DOES Fretish GATHER ABOUT ITS USERS?

Information that you give us
We receive, store and process information, including Personal Information, that you make available to us when accessing or using our Platform and Services. Examples include when you:


fill in any form on the Platform, such as when you register or update the details of your user account, or when you supply ID and other verification information;

access or use the Platform, such as to search for or post Equipments, make or accept bookings, pay for Equipments, book or pay for any associated services that may be available (such as but not limited to cleaning), post comments or reviews, or communicate with other users;

link your account on a Third-Party site (e.g. Facebook) to your Fretish Account, in which case we will obtain the Personal Information that you have provided to the Third-Party site, to the extent allowed by your settings with the Third-Party site and authorized by you;

communicate with Fretish; and

share information with another Member.


Information we get from your use of our Platform
We also receive, store and process information, possibly including Personal Information, when you access or use our Platform and Services, including but not limited to:


Mobile Data
When you use certain features of the Platform, in particular our mobile applications we may receive, store and process different types of information about your location, including general information (e.g. IP address, zip code) and more specific information (e.g. GPS-based functionality on mobile devices used to access the Platform or specific features of the platform). If you access the Platform through a mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this. See your device manufacturer’s instructions for further details.


Contact Information
You may use your contact information, such as your email address, phone number or WeChat account ID to create or customize your account or to enable certain account features, for example, for login verification. If you provide us with your email address, phone number or WeChat account ID, you agree to receive emails to that email address, text messages to that phone number or messages to that WeChat account, as the case may be. We may use your contact information to send you information about our Platform and Services, to market to you, and to help prevent spam, fraud, or abuse.


Log Data
We may also receive, store and process Log Data, which is information that is automatically recorded by our servers whenever you access or use the Platform, regardless of whether you are registered with Fretish or logged in to your Fretish Account, such as your IP Address, the date and time you access or use the Platform, the hardware and software you are using, referring and exit pages and URLs, the number of clicks, device event information, pages viewed and the order of those pages, and the amount of time spent on particular pages.


Cookies and other Tracking Technologies
Fretish uses cookies and other similar technologies, such as mobile application and other device identifiers, on the Platform. We may also allow our business partners to use their cookies and other tracking technologies on the Platform. As a result, when you access or use the Platform, you will provide or make available certain information to us and to our business partners.

While you may disable the usage of cookies through your browser settings, we do not change our practices in response to a “Do Not Track” signal in the HTTP header from your browser or mobile application. We track your activities if you click on advertisements for Fretish services on Third-Party platforms such as search engines and social networks, and may use analytics to track what you do in response to those advertisements.

We may, either directly or through Third Parties we engage to provide services to us, also continue to track your behavior on our own Platform for purposes of our own customer support, analytics, research, product development, fraud prevention, risk assessment, regulatory compliance, investigation, as well as to enable you to use and access the Platform and pay for your activities on the Platform. We may also, either directly or through Third-Parties we engage to provide services to us, track your behavior on our own Platform to market and advertise our services to you on the Platform and Third-Party websites. Third Parties that use cookies and other tracking technologies to deliver targeted advertisements on our Platform and/or Third-Party websites may offer you a way to prevent such targeted advertisements by opting-out at the websites of industry groups such as the Network Advertising Initiative and/or the Digital Advertising Alliance. You may also be able to control advertising cookies provided by publishers, for example Google’s Ad Preference Manager. Please note that even if you choose to opt-out of receiving targeted advertising, you may still receive advertising on or about the Platform – it just will not be tailored to your interests. In addition, if you disable cookies, you may lose some of the features and functionality of using our Platform, Application and Services, as cookies are necessary to track and enhance your use and access.

Third Parties may not collect information about users’ online activities on the Platform except as described in this policy and our Cookie Policy.


Third-Party social plugins
Our Platform may use social plugins which are provided and operated by Third-Parties, such as Facebook’s Like Button.

As a result of this, you may send to the Third-Party the information that you are viewing on a certain part of our Platform. If you are not logged into your account with the Third-Party, then the Third Party may not know your identity. If you are logged into your account with the Third Party, then the Third Party may be able to link information about your visit to our Platform to your account with them. Similarly, your interactions with the social plugin may be recorded by the Third Party.

Please refer to the Third Party’s privacy policy to find out more about its data practices, such as what data is collected about you and how the Third Party uses such data.



HOW Fretish USES AND PROCESSES THE INFORMATION THAT YOU PROVIDE OR MAKE AVAILABLE 

We use, store and process information about you for the following general purposes: 

to enable you to access and use the Platform;

to enable you to communicate with other Members, including but not limited to by sending them messages or other information during the Booking process;

to operate, protect, improve and optimize the Platform, Fretish’s business, and our users’ experience, such as to perform analytics, conduct research, personalize or otherwise customize your experience, and to provide customer service;

to help create and maintain a trusted and safer environment on the Platform and Services, such as detection and prevention of actual and potential fraud and other harmful activity, conducting investigations and risk assessments, enforcing our Terms and policies, verifying the address of your listings, verifying any identifications provided by you (including by comparing the photo on that identification to another photo you provide to us), and conducting checks against databases and information sources (such as but not limited to public government databases) for fraud detection and prevention, risk assessment and harm prevention purposes. In this regard, we may do any or all of the foregoing with or without further notifying you;

to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;

to send you marketing, advertising, and promotional messages and other information that may be of interest to you, including information about Fretish, our services, or general promotions for partner campaigns and services. You can unsubscribe or opt-out from receiving these communications in your settings (in the “Account” section) when you login to your Fretish Account;

if a Renter has an employment or consulting relationship with a company or other organization that participates in the Fretish Business Travel Program, and that Renter has linked their Fretish Account to that organization, to administer the Fretish Business Travel Program;

to administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Fretish or our Third Party business partners; and

to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with Third Parties.


How Fretish Uses and Processes User Communications
We may, either directly or through Third-Parties we engage to provide services to us, review, scan, or analyze your communications with other users exchanged via the Platform for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research and customer support purposes. For example, as part of our fraud prevention efforts, the Platform may scan and analyze messages and attachments to mask contact information and references to other websites. This helps to prevent fraudulent actors from asking Renters to send them money outside of the Platform, such as by bank transfer or other money transfer methods. We may also scan, review or analyze messages for research and product development purposes to help make search, booking and user communications more efficient and effective, as well as to debug, improve and expand product offerings. We will not review, scan, or analyze your communications for sending Third-Party marketing messages to you. We will also not sell these reviews or analyses of communications to Third Parties. We will also use automated methods to carry out these reviews or analyses where reasonably possible. However, from time to time we may have to manually review some communications. By using the Platform, you consent that Fretish, in its sole discretion, may, either directly or through Third-Parties we engage to provide services to us, review, scan, analyze, and store your communications, whether done manually or through automated means.



WHEN Fretish DISCLOSES OR SHARES YOUR PERSONAL INFORMATION, AND TO WHOM
IMPORTANT: When you use the Platform, your data may be sent to the United States and possibly other countries in accordance with this Privacy Policy.

We may transfer, store, use and process your information, including any Personal Information, to countries outside of the European Economic Area (“EEA”) including the United States and possibly other countries. By using the Platform, you consent to transferring your data to these countries. Please note that laws vary from jurisdiction to jurisdiction, and so laws and regulations relating to privacy and data disclosure, applicable to the places where your information is transferred to or stored, used or processed in, may be different from the laws and regulations applicable to the place where you are resident.

Fretish, Inc. complies with the US-Swiss Safe Harbor Framework and principles, as described in its certification (https://safeharbor.export.gov/companyinfo.aspx?loc=swiss&id=32707) If you are located in Switzerland, please also see our Safe Harbor Notice (https://www.Fretish.ch/terms/safe_harbor_notice).

In addition, if you reside outside of China and you create a Listing in China, book an Equipment in China or message the Owner of a Listing in China, this paragraph applies to you: When you take any action that would result in any transfer, storage, use or processing of your Personal Information in or to China, we will notify you before any such transfer, storage, use or processing is undertaken. We will also notify you if we adopt any practices for China that differ from what is described in this Privacy Policy, including any practices pertaining to disclosures to Chinese government agencies; otherwise all of the provisions of this Privacy Policy will apply.

Your Personal Information may be transferred, stored, used, processed and disclosed as follows:


Parts of your public profile page that contain some Personal Information may be displayed in other parts of the Platform to other users for marketing purposes or if you post content in a community forum or other features on the Platform that are visible to the general public.

Your public Listing page will always include some minimum information such as the city and neighborhood where the Equipment is located, your listing description, your calendar availability, your public profile photo, your responsiveness in replying to Renters’ queries, and any additional information you share with other Members. Your public Listing page may also include aggregated demand information (such as number of page views over a period of time). Parts of your public Listing page may be displayed in other parts of the Platform to other Members and/or Third Party platforms for marketing purposes. The Platform may also display the Equipment’s approximate geographic location on a map, such that a user can see the general area of the Equipment.

The Platform allows your public profile and public Listing pages to be included in search engines, in which case your public profile and public Listing pages will be indexed by search engines and may be published as search results. This option is enabled by default, and you may opt out of this feature by changing your settings on the Platform. If you change your settings or the information on your public profile or public Listing pages, Third-Party search engines may not update their databases quickly or at all. We do not control the practices of Third-Party search engines, and they may use caches containing outdated information, including any information indexed by the search engine before you change your settings or the information on your public profile or public Listing pages.

When you submit a request to book an Equipment, your full name, and the full name of any confirmed Renters staying with you, and other Personal Information you agree to pass through to the Owner(s) will become visible to the Owner(s) of any Listing you Book or request to Book. We may also disclose parts of your public profile; your public Wish List; other Member reviews of you; and any additional information you share with other Members. In addition, if you agree to be contacted by the Owner(s) by phone before your request to Book is accepted, and the Owner(s) decides to do so, Fretish will call your phone number first, before connecting you with the Owner(s). We will not share your phone number unless there is a confirmed booking; if there is a confirmed booking, your phone number will become visible to the Owner(s)/Renter, who may call you directly.

When your request to book an Equipment is accepted by the Owner(s) or when a Renter books your Equipment, we will disclose some of your Personal Information to the Owner(s) and any confirmed Renter(s). However, your billing and payout information will never be shared with another user.

If a Renter books an Equipment for a business trip, and the Renter is engaged or employed by a company or other organization (either or both a “Renter Affiliated Organization”) that is enrolled in our Business Travel Program, we may disclose the name of the Owner and the address and other Equipment information to the Renter Affiliated Organization. If the Renter or the Renter Affiliated Organization uses any Third Party for travel management, financial reporting and/or travel related crisis management services (collectively, “Business Travel Services”), we may also share Owner and Equipment information with those Third Parties and any service providers of those Third Parties who participate in providing such Business Travel Services.

Notwithstanding that you do not reside in China, some of your Personal Information will be transferred to, stored, used and processed by Fretish China in the following circumstances: 

When you create a Listing in China, (i) your name and phone number, (ii) all information relating to the Listing including its address, (iii) booking information relating to the Listing (such as Renter details as set out in paragraph (b) below, booking dates and payment amounts), and (iv) messages between you and prospective and confirmed Renters at the Listing.

When you book an Equipment in China, (i) your name and phone number, (ii) booking dates, (iii) messages between you and the Owner, and (iv) the names, nationality(ies), passport/national ID number(s) and passport expiry date(s) of the Renter(s).

When you send a message to a Owner in relation to that Owner’s Listing in China, your first name, profile picture and message content via the Fretish platform.


When a Owner accepts your request to book an Equipment, the Owner may elect to use Third-Party services available through the Fretish platform to assist with managing the Equipment, such as cleaning services and lock providers. The Owner may use features on the Fretish platform to share information about the Renter with that Third-Party service provider for the purposes of coordinating the stay or managing the Equipment, including check-in and check-out dates, Renter name, Renter’s phone number, and the Renter’s anonymized email address.

If you as a Renter are associated with a Renter Affiliated Organization, we may share with it information related to your bookings through the Business Travel Program. Further, if you have linked your Fretish Account to a Renter Affiliated Organization and indicate that a booking is for business purposes, we may disclose your booking information (which may include your Personal Information) to such organization. Typically this information will include your name, dates of the booking, number of Renters, cost of the booking, and the address of the booking. In addition, if your Renter Affiliated Organization has requested that we provide it with information in the event of a dispute, emergency or similar situation involving your bookings through the Business Travel Program, we may notify such organization of the situation and disclose to it any information, including your Personal Information, that we believe in good faith is necessary to safely and quickly resolve or address the situation. If you or your Renter Affiliated Organization uses a Third Party for travel management, financial reporting, and/or travel related crisis management services, we may also disclose your booking information, or information related to a dispute, emergency or similar situation involving you, to those Third Parties and any service providers of those Third Parties who participate in providing such services.

When a Renter stays at your Equipment or when you stay at a Owner’s Equipment, we may ask you to review the Renter, Owner, or the Equipment. If you choose to provide a review, your review may be public on the Platform. Likewise, another Member’s review of you as a Renter or Owner may be public on the Platform.

You may link your account on a Third-Party social networking site to your Fretish Account. We refer to a person’s contacts on these Third-Party sites as “Friends”. When you create this linkage: 

some of the information you provide to us from the linking of your accounts may be published on your Fretish Account profile;

your activities on the Platform may be displayed to your Friends on the Platform and/or that Third-Party site;

a link to your public profile on that Third-Party social networking site may be included in your Fretish public profile;

other Fretish users may be able to see any common Friends that you may have with them, or that you are a Friend of their Friend if applicable;

other Fretish users may be able to see any schools, hometowns or other groups you have in common with them as listed on your linked social networking site(s);

the information you provide to us from the linking of your accounts may be stored, processed and transmitted for fraud prevention and risk assessment purposes; and

the publication and display of information that you provide to Fretish through this linkage is subject to your settings and authorizations on the Platform and the Third-Party site.


We may distribute parts of the Platform (including your Listing) for display on sites operated by Fretish’s business partners and affiliates, using technologies such as HTML widgets. If and when your Listings are displayed on a partner’s site, information from your public profile page may also be displayed.

Fretish may provide your Personal Information to its Affiliates, including Fretish Payments, and their employees, to use and process your Personal Information in the same way and to the same extent that we are permitted to under this Privacy Policy. These related entities comply with the same obligations that we have to protect your Personal Information under this Privacy Policy. Fretish Payments may share your Personal Information for (i) their everyday business purposes; (ii) to jointly market products or services to you with other financial Third Parties with whom Fretish Payments has a formal agreement; and (iii) with respect to information about your transactions and experiences only, for their Affiliates’ everyday purposes. You can unsubscribe or opt-out from receiving marketing communications in your settings (in the “Account” section) when you login to your Fretish account.

We may also engage Third Parties, who may be located outside of the EEA, to provide services to us, including but not limited to technology services and services to help verify your identification, to help match the photo on your ID to other photos of yourself you send to us, to conduct checks against databases such as but not limited to public government databases (where legally allowed), to otherwise assist us with fraud prevention and risk assessment, to assist us with customer service, to serve targeted ads, and to facilitate the payments or reimbursements you request (such as Concur and American Express). We may provide Personal Information about you to these Third Parties, or give them access to this Personal Information, for the limited purpose of allowing them to provide these services. For example, if we hire Third Parties, where permitted by applicable law, to conduct checks against databases such as but not limited to public government databases, we may provide your Personal Information, such as your full name and date of birth, to the Third Parties for the limited purpose of allowing them to conduct such checks, including background or registered sex offender checks, on our behalf. We will ensure that such Third Parties have contractual obligations to protect this Personal Information and to not use it for unrelated purposes.

For any jurisdiction in which we facilitate the Collection and Remittance of Taxes or Opt-in for Owner Remittance of Taxes as described in the “Taxes” section of the Terms of Service, Owners and Renters expressly grant us permission, without further notice, to store, transfer and disclose data and other information relating to them or to their transactions, bookings, Equipments and Occupancy Taxes, including, but not limited to, personally identifiable information such as Owner or Renter’s name, listing addresses, transaction dates and amounts, tax identification number(s), the amount of taxes received by Owners from Renters, or allegedly due, contact information and similar information, to the relevant Tax Authority.

You acknowledge, consent and agree that Fretish may access, preserve and disclose your account information and Collective Content if required to do so by law or in a good faith belief that such access, preservation or disclosure is reasonably necessary (a) to respond to claims asserted against Fretish; (b) to comply with legal process (for example, subpoenas and warrants), including legal process associated with national security and law enforcement; (c) to enforce and administer our agreements with users, such as the Terms of Service, the Payments Terms of Service, this Privacy Policy, and the Owner Guarantee Terms and Conditions; (d) for fraud prevention, risk assessment, investigation, customer support, product development and de-bugging purposes; or (e) to protect the rights, property or personal safety of Fretish, its users or members of the public.
We will use commercially reasonable efforts to notify users about law enforcement requests for their data unless:


providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law; or

we believe that providing notice would (a) be futile, (b) be ineffective, or (c) would create a risk of injury or bodily harm to an individual or group, or (d) create or increase a risk of fraud upon Fretish’s property, its Members, the Platform, Application, or Services (collectively, “Risk Scenarios”).

In instances where Fretish complies with legal requests for user data without notice to the user for the reasons described above, Fretish will use commercially reasonable efforts to notify that user about the request after the fact if we determine in good faith that we are no longer legally prohibited from doing so and that no Risk Scenarios apply.


We may also publish, disclose and use Aggregated Information and non-personal information for industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.


STATE PRIVACY LAWS
For California & Vermont residents: Fretish Payments will not share information it collects about you with Affiliates or Third Parties, except as required or permitted by your state’s law.


BUSINESS TRANSFERS BY Fretish
If Fretish undertakes or is involved in any merger, acquisition, reorganization, sale of assets or bankruptcy or insolvency event, then we may sell, transfer or share some or all of our assets, including your Personal Information. In this event, we will notify you before your Personal Information is transferred and becomes subject to a different privacy policy.


HOW TO ACCESS, CHANGE OR DELETE YOUR INFORMATION, OR CANCEL YOUR Fretish ACCOUNT
You may review, update, correct or delete the Personal Information in your Fretish Account. If you would like to correct your information or cancel your Fretish Account entirely, you can do so by logging in to your Fretish Account. Please also note that any reviews, forum postings and similar materials posted by you may continue to be publicly available on the Platform in association with your first name, even after your Fretish Account is cancelled.


SECURING YOUR PERSONAL INFORMATION
We are continuously implementing and updating administrative, technical, and physical security measures to help protect your Personal Information against unauthorized access, destruction or alteration. However, no method of transmission over the Internet, and no method of storing electronic information, can be 100% secure. So, we cannot guarantee the security of your transmissions to us and of your Personal Information that we store.


YOUR PRIVACY WHEN YOU ACCESS THIRD-PARTY WEBSITES AND RESOURCES
The Platform will contain links to other websites not owned or controlled by Fretish. Fretish does not have any control over Third-Party websites. These other websites may place their own cookies, web beacons or other files on your device, or collect and solicit Personal Information from you. They will have their own rules about the collection, use and disclosure of Personal Information. We encourage you to read the terms of use and privacy policies of the other websites that you visit.

Some portions of the Platform implement Google Maps/Earth mapping services, including Google Maps API(s). Your use of Google Maps/Earth is subject to Google’s terms of use (located at www.google.com/intl/en_us/help/terms_maps.html) and Google’s privacy policy (located atwww.google.com/privacy.html), as may be amended by Google from time to time


SPECIAL FEATURES AND PROGRAMS

Referral service and requesting references
The Platform provides a referral service that allows you to invite your friends and contacts to use the Platform. The Platform also allows you to ask your friends and contacts to write a reference for you, to be published on your Fretish profile.

We may integrate the Platform with third party sites such as Facebook, so that you can send invitation messages or requests for references via the third party site itself. These messages will be sent by the third party site, and Fretish does not collect or retain the contact information that is used to send them.

You may also send invitation/request emails via the Platform itself, in which case we will ask you for the contact information to which to send your invitation/request. You can type in the email addresses or other contact information manually, or you can choose to import the contacts in your address book(s). In both cases, we may use and store this information for the sole purposes of allowing you to send your friends and contacts an invitation or request for a reference, and for fraud detection and prevention. With respect to referrals, we will also store the email addresses of your invitees to track if your friend joins Fretish in response to your referral.

If you request us to import your contacts, we will collect, but not store, the username and password for the email account you wish to import your contacts from. We will use this information only for the purpose of importing your contacts.


Affiliate Program
If you are allowed to join Fretish’s Affiliate Program and you sign up for it, you will have to provide us with certain Personal Information to enable us to provide the Affiliate Program to you.


Meetups
The Platform may allow registered account holders to organize, search for or participate in offline events (“Meetups”) in selected cities.

If you organize a Meetup or indicate that you will attend one, this information, together with some of your public information (such as your profile picture and public profile page) and any messages that you post about that Meetup, will be visible to users who browse the event. However, Fretish will never disclose where you are staying to another meetup user.



CHANGES TO THIS PRIVACY POLICY
We may change how we collect and then use Personal Information at any time and without prior notice, at our sole discretion. We may change this Privacy Policy at any time. If we make material changes to the Privacy Policy, we will notify you either by posting the changed Privacy Policy on the Platform or by sending an email to you. We will also update the “Last Updated” date at the top of this Privacy Policy. If we let you know of changes through an email communication, then the date on which we send the email will be deemed to be the date of your receipt of that email.

It’s important that you review the changed Privacy Policy. If you do not wish to agree to the changed Privacy Policy, then we will not be able to continue providing the Platform and Services to you, and your only option will be to stop accessing the Platform and Services and deactivate your Fretish Account. You can find out more about how to deactivate your Fretish Account at www.Fretish.com/help.


GOT FEEDBACK?
Your opinion matters to us! If you’d like to provide feedback to us about this Privacy Policy, please email us at sam@fretish.com. For all other questions or concerns, please email us at www.Fretish.com/contact.


FOR USERS RESIDING IN THE EU AND JAPAN ONLY: YOUR RIGHTS TO REVIEW AND UPDATE INFORMATION
If you reside in the EU or Japan, you may request in writing copies of your Personal Information held by us. We will provide you with a copy of the Personal Information held by us as soon as practicable and in any event not more than 40 days after receiving a valid request in writing. There may be a charge to access your personal data (which will not exceed €6.35 in Ireland and £10 in the United Kingdom, and will not be applicable in Japan). We may also request proof of identification to verify your access request.

We endeavor to keep your information accurate, complete and up to date. If your Personal Information that we hold is inaccurate, please let us know and we will make the necessary amendments, erase or block the relevant information and notify you within 40 days of your valid request that the relevant action has been taken.

You may also request the erasure of your Personal Information if you believe we are otherwise in breach of relevant data protection legislation. All requests should be addressed to our Data Protection Compliance Officer, Fretish Ireland, Watermarque Building, South Lotts Road, Ringsend, Dublin 4, Ireland. There is no charge for making such a request.


FOR USERS RESIDING IN THE EU: YOUR RIGHT TO SEE AND CHALLENGE INFORMATION PROVIDED TO US BY THIRD PARTIES
You are entitled to see and challenge any information that Third Parties may provide to us as part of our fraud detection, prevention and risk assessment efforts in circumstances where all of the following factors apply: (i) if we use Third Parties to carry out automated checks or risk assessments, and (ii) if we make a decision which has legal consequences for you or which significantly affects you, and (iii) if such decision is based solely on such automated checks or risk assessments. In order to request this, please address your request directly to Fretish Ireland, Privacy Office, Watermarque Building, South Lotts Road, Ringsend, Dublin 4, Ireland. Please state clearly in your request that you wish to see and/or challenge the information that Third Parties may have provided to Fretish as part of our fraud detection, prevention and risk assessment efforts. We may request proof of identification to verify your request.

Fretish is subject to the authority of the Federal Trade Commission and has certified with the Privacy Shield as required by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from the European Union member countries. Fretish certifies that it adheres to the Privacy Shield principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. Consistent with these principles, where Fretish uses service providers to process personal data of European Union residents, Fretish shall remain liable where the agent processes such personal data of European Union residents in a manner inconsistent with the Privacy Shield principles, except where Fretish establishes that Fretish is not responsible for the damages caused by the agent. To learn more about the Privacy Shield program, and to view the list of entities who have current certifications under the Privacy Shield, please visit the U.S. Department of Commerce’s Privacy Shield List.

If you have any questions or complaints about Fretish’s privacy practices, you may contact Fretish at Fretish Ireland, Privacy Office, Watermarque Building, South LottsRoad, Ringsend, Dublin 4, Ireland, and we will work with you to resolve your issue. As a resident of the European Union, you may also contact your appropriate European Data Protection Authority with questions or complaints about our privacy practices.

Residents of the European Union who are dissatisfied with the way in which we have addressed your concerns about our privacy practices may seek further assistance from our designated Privacy Shield independent recourse mechanism, JAMS.

Residents of the European Union who have unresolved complaints after: (1) contacting Fretish to resolve the issue; (2) seeking assistance from our independent recourse mechanism; and (3) contacting the U.S. Department of Commerce (either directly or through a European Data Protection Authority) and giving the Department of Commerce time to attempt to resolve the issue, may elect to arbitrate certain claims. See here for more details. Claims shall be arbitrated free of charge by our arbitration provider, the American Arbitration Association ("AAA"), though each party will be responsible for its own attorney’s fees. Please be advised that, pursuant to the Privacy Shield, the arbitrator(s) may only impose individual-specific, non-monetary, equitable relief necessary to remedy any violation of the Privacy Shield Principles only with respect to the individual.


COOKIE POLICY
Fretish uses “cookies” in conjunction with the Platform to obtain information. A cookie is a small data file that is transferred to your device (e.g. your phone or your computer) for record-keeping purposes. For example, a cookie could allow the Platform to recognize your browser, while another could store your preferences and other information.

Your browser may allow you to set how it handles cookies, such as declining all cookies or prompting you to decide whether to accept each cookie. But please note that some parts of the Platform may not work as intended or may not work at all without cookies.


Fretish cookies and Third Party cookies
Fretish may place our cookies on your device via the Platform. Accordingly, our Privacy Policy will apply to our treatment of the information we obtain via our cookies.

We may also allow our business partners to place cookies on your device. For example, we use Google Analytics for web analytics, and so Google may also set cookies on your device. As further explained below, Third Parties may also place cookies on your device for advertising purposes.

There are two types of cookies used on the Platform, namely “persistent cookies” and “session cookies”.

Session cookies will normally expire when you close your browser, while persistent cookies will remain on your device after you close your browser, and can be used again the next time you access the Platform.


Other technologies
The Platform may also use other technologies with similar functionality to cookies, such as web beacons and tracking URLs to obtain Log Data about users. We may also use web beacons and tracking URLs in our messages to you to determine whether you have opened a certain message or accessed a certain link.


Uses for Fretish cookies
Fretish uses cookies and similar tracking technologies for a number of purposes, such as the following:

  • to enable, facilitate and streamline the functioning of the Platform across different webpages, devices and browser sessions.
  • to simplify your access to and use of the Platform and make it more seamless.
  • to monitor and analyze the performance, operation and effectiveness of the Platform, so that we can improve and optimize it.
  • to show you content (which may include advertisements) that is more relevant to you.
  • for fraud detection and prevention.


Uses for Third-Party cookies
Our partners’ cookies are intended to obtain information to help them provide services to Fretish. For example, Third Parties we engage to provide services to us may track your behavior on our Platform to market and advertise Fretish listings or services to you on the Platform and Third-party websites, or to help us detect or prevent fraud or conduct risk assessments. Third Parties websites that use cookies and other tracking technologies to deliver targeted advertisements on our Platform and/or Third-Party websites may offer you a way to prevent such targeted advertisements by opting-out at the websites of industry groups such as the Network Advertising Initiative and/or the Digital Advertising Alliance. You may also be able to control advertising cookies provided by publishers, for example Google’s Ad Preference Manager. Please note that even if you choose to opt-out of receiving targeted advertising, you may still receive advertising on or about the Platform – it just will not be tailored to your interests.

In addition, Facebook places a cookie via the Platform that allows Facebook to obtain aggregated, non-Personal Information to optimize their services. For example, if a user clicks on an advertisement for the Fretish mobile app on Facebook and subsequently installs the app, this cookie will inform Facebook that a user (who is not personally identified) has installed the app after clicking on the advertisement. This cookie may also inform Facebook that a user is using the app, without identifying the specific actions taken by the user in the app.


Disabling Cookies
Most browsers automatically accept cookies, but you can modify your browser setting to decline cookies by visiting the Help portion of your browser’s toolbar. If you choose to decline cookies, please note that you may not be able to sign in, customize, or use some of the interactive features of the Platform. Flash cookies operate differently than browser cookies, and cookie management tools available in a web browser will not remove flash cookies. To learn more about how to manage flash cookies, you can visit the the Adobe website and make changes at the Global Privacy Settings Panel.


Changes to this Cookie Policy
We can change this Cookie Policy at any time. If we make material changes to the Cookie Policy, we will let you know either by posting the changed Cookie Policy on the Platform or by sending you an email.

It’s important that you review the changed Cookie Policy. If you do not wish to agree to the changed Cookie Policy, then we cannot continue to provide the Platform to you, and your only option is to stop accessing the Platform and Services and deactivate your Fretish Account. You can find out more about how to deactivate your Fretish Account at www.Fretish.com/help.

Contact person

Sam T

Boston, MA 02116
sam@fretish.com