What Information We Collect
We use "cookies" to keep track of some types of information while you are visiting our website or using the Service. Cookies are very small files placed on your computer, and they allow us to count the number of visitors to our website and distinguish repeat visitors from new visitors. They also allow us to save user preferences and track user trends. We rely on cookies for the proper operation of our Service. If your browser rejects cookies from the Service, then the Service will not function properly with your browser, and we are not responsible for any resulting loss of functionality in the Service.
We use third-party analytics service providers (“Analytics Providers”), such as Google and Amazon AWS, to help us analyze how users use the Service. We may change the Analytics Providers that we use from time to time. The information generated by your browser or device about your use of the Service will be transmitted to and stored by the Analytics Provider(s) on servers in the United States. The Analytics Providers will use this information for the purpose of evaluating users’ use of the Service, compiling reports on website or mobile activity for our use and providing other services relating to Service activity and Internet usage. The Analytics Providers may also transfer this information to third parties where required to do so by law, or where such third parties process the information on the Analytics Providers’ behalf. By using the Service, you consent to the processing of data about you by the Analytics Provider in the manner and for the purposes set out above.
If you enable location-based services by the Service and your mobile device, the Service may collect data about your geographic location. Such location data may include, for example, geographic coordinates or other data used to determine your location (using GPS, IP address, Wi-Fi, or other technology to determine the location of your device), the time when such data is collected, and a non-PII identifier that we may use to correlate such data to you (collectively, the “Location Data”). The Location Data may be collected, stored, and processed by us and/or by our third-party location licensors or service providers. We may use the Location Data to analyze usage of the Service, to improve the Service, and to provide the Service to you (e.g., by providing you with location-based recommendations of places we think you might want to visit through the Service when you are exploring a new city).
However, it is important to note that:
• (a) We will not share Location Data with anyone other than our licensors or service providers who provide the location services for the Service.
• (b) If any such third-party licensor or service provider collects, stores, or processes any Location Data for the Service, we contractually require that they not use the Location Data for their own purposes (other than analyzing and improving their location products and services) or share this data with anyone but us (other than aggregated, anonymized data that does not identify any individuals).
• (c) You may enable or disable location services at any time using the settings in the app and/or your device’s operating system.
"Web beacons" (also known as "clear gifs" and "pixel tags") are small transparent graphic images that are often used in conjunction with cookies in order to further personalize our website for our users and to collect a limited set of information about our visitors. We may also use web beacons in email communications in order to understand the behavior of our customers. We do not link the web beacons to any PII.
Information About You
We require an email address from you when you register for the Service. We use your email both for transactional purposes (e.g., activity updates such as notices that another user is now following you on the Service) and for promotional purposes (e.g., newsletters, new product offerings, event notifications, special third-party offers). Email messages we send you may contain code that enables our database to track your usage of the emails, including whether the email was opened and what links (if any) were clicked. If you would rather not receive promotional emails from us, please see the section below labeled "Choice/Opt-Out". We reserve the right to send you certain communications, such as service announcements and administrative messages, without offering you the opportunity to opt out of receiving them. We may also contact you by text message (including to any wireless number you may provide to us) solely in connection with the Service. If you would rather not receive text messages from us, you may change or delete your number from your "Account Settings" page, or ask to be removed from our contact list if you receive a call or text message from us. We fully comply with the requirements of the U.S. CAN-SPAM Act.
Demographic data is also collected by the Service. We use this data to tailor our visitors' experience, showing them content that we think they might be interested in, and displaying the content according to their preferences. Some of this information may be shared with advertisers on a non-personally identifiable basis.
Online Survey Data
We may periodically conduct voluntary member surveys. We encourage our members to participate in such surveys because they provide us with important information regarding the improvement of the Service. You may also volunteer for certain surveys that we may offer to our users, and any additional rules regarding the conduct of such surveys will be disclosed to you prior to your participation.
Information Regarding Your Friends
We offer contact importer tools to help you upload your friends' addresses so that you can find your friends on the Service, and invite your contacts who do not have Cabinet accounts to join. If you give us your password to retrieve those contacts, we will not store your password after you have uploaded your contacts' information. We will send your designated contacts one or more email messages containing your name and inviting them to participate in the Service, which may include follow-up or reminder messages. These emails will also include instructions on how to remove their information from our database.
We make discussion areas available to our Service's users and visitors. Any information that is disclosed in these areas becomes public information and you should exercise caution when deciding to disclose any PII. Please consult the Community Guidelines when posting comments on them for other specific information.
Disclosure of Your Information to Third Parties
Disclosure Authorized or Required By Law. You acknowledge and agree that we may disclose information you provide if:
• (a) we believe in good faith that we are authorized or required to do so by law, including to respond to requests or orders relating to law enforcement, national security, or any legal process; or
• (b) you give us your consent to do so, including if we notify you that the information you provide will be shared in a particular manner and you provide such information; or
• (c) we believe that disclosure is reasonably necessary or appropriate to protect or defend the rights or property of us or a third party or to protect someone's health or safety.
Disclosure to Trusted Third Parties By Us.
We may share and/or make available your publically accessible information such as your name, profile picture, reviews, traveller photos and posts (which may include PII) to carefully selected third parties with whom we have a contractual relationship. We may share your PII, sometimes in conjunction with your non-PII, with service providers that may be associated with us to perform functions on our behalf. For example, outsourced customer support agents or technology infrastructure providers (such as a provider of location services, as described above) may need access to your information to perform services for you. We require that your information be treated as private and confidential by such service providers and not be used for any other purpose than we authorize. In addition, from time to time, we may share PII (such as email or mailing address) about our user base with carefully selected third parties, so they can offer goods and services that we believe may be of interest to our users. If you do not wish to receive offers from our trusted partners, you can change your email preferences at any time by following the steps outlined in the "Choice/Opt-Out" section below. We are potentially liable for the onward transfer of an EU individual’s PII to third parties.
We may share and/or transfer your information (both PII and non PII) to our group companies.
Information Transferred As a Result of Sale of Business. In the event that we are acquired by another company, your PII may be part of the assets transferred to the acquiring party. If this occurs, you will be notified if there are any material changes to the way your PII is collected or used.
Data Stored in the US
EU-U.S. Privacy Shield Framework
In compliance with the Privacy Shield Principles, we commit to resolve complaints about our collection or use of your personal information. European Union individuals with inquiries or complaints regarding our Privacy Shield policy should first contact us at firstname.lastname@example.org.
We have further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.
The Federal Trade Commission has jurisdiction with enforcement authority over our compliance with the Privacy Shield.
Under certain conditions, you may have the right to invoke binding arbitration for complaints regarding Privacy Shield compliance not resolved by any of the other Privacy Shield mechanisms. For more information on binding arbitration, see https://www.privacyshield.gov/article?id=ANNEX-I-introduction
We have security measures in place that are designed to protect against the loss, misuse and alteration of the information stored in our database. We will exercise reasonable care in providing secure transmission of information between your computer or mobile device and our servers. However, no information transmitted over the Internet can be guaranteed 100% secure, so we cannot ensure or warrant the security of any information transmitted to us over the Internet and accept no liability for any unintentional interception or misuse.
Links to Other Sites
You may use the following options for removing your information from our email mailing list if you wish to opt out of receiving promotional emails and newsletters.
• Click on the "unsubscribe" link on the bottom of the email;
• Click on the "Account Settings" link from our website or mobile app, and un-check the undesired promotions.
In addition, some of the third-party advertising agencies who advertise on the Service may be members of the Network Advertising Initiative, which offers you the option to opt out of ad targeting from its member agencies by following the procedures listed at Networkadvertising.org.
Updating or Removing Your Information
We acknowledge the individual’s right to access his or her personal data. You may view your data, change your email address, password and other information from the "Account Settings" page accessible via a link from our website and mobile application. To the extent you choose to include PII or other information in your profile, the Service allows you to update or remove that information by editing or deleting the content.
This privacy statement was last revised on December 3, 2019.