Privacy Policy in accordance with Article 13 of Legislative Decree no. 196/2003 and Article 13 of EU Regulation no. 2016/679.
Last updated: 10 May 2021
The mission of HQVillage is to help establish connections between people and promote a healthy way of living and working in places that are useful for smartworkers and digital nomads. In short, we want to create a world where anyone can choose where to work, anywhere. We are a community built on trust. A key part of earning that trust is being clear about how we use your information and protecting your human right to privacy.
This Privacy Policy describes how WELL-FARE S.R.L. as the Company that owns HQVillage and its affiliates (“we”, “us” or “HQVillage”) treat the personal information we collect through the HQVillage Platform. Depending on where you live and the type of activity you carry out on the HQVillage Platform, different conditions may apply, in which case you can follow the dedicated links or ask us for more information directly.
IMPORTANT ADDITIONAL INFORMATION
Outside the United States. If you are located outside the United States, for example, in the European Economic Area (“EEA”) please read the “Outside the United States” section to learn about (i) the controller(s) of your personal information; (ii) the legal basis, including legitimate interests, for collecting and processing your personal information (iii) the safeguards we rely on to transfer your personal information outside the EEA; (iv) your rights; and (v) the contact details of the data controller(s) and the Data Protection Officer.
Business Customers and HQVillage for Work. If you use our business services or have linked your account to a business customer, please read the “Business Customers” section for specific privacy information applicable to you.
Summary
1. Definitions
2. Object
3. Data controller
4. Purpose of processing
5. Personal information we collect
6. How we use the data we collect
7. Sharing and disclosure
8. Other important information
9. Your rights
10. Security
11. Changes to this Privacy Policy
12. Contact information and responsible parties of HQVillage
4. Processing and storage methods
5. Period of data retention
6. Scope of communication and dissemination
7. Transfer of personal data
8. Special categories of personal data
9. Existence of automated decision making, including profiling
10. Rights of the data subject
1. DEFINITIONS
Terms that are not defined in this Privacy Policy have the same meaning as described in our “Terms of Service” (“Terms”).
2. OBJECT
Pursuant to art. 13 of Legislative Decree 196/2003 (hereinafter also referred to as the “Privacy Code”) and art. 13 of EU Regulation no. 2016/679 (hereinafter also referred to as the “GDPR 2016/679”), containing provisions for the protection of persons and other subjects with regard to the processing of personal data, we wish to inform you that the personal data provided by you will be processed in compliance with the aforementioned legislation and with the confidentiality obligations to which the company WELL-FARE S.r.l., with registered office in Pontedera (PI) – Via Giordano Bruno 21, is bound.
3. Data Protection Officer (DPO)
The data protection officer for the company WELL-FARE S.r.l. with registered office in Pontedera (PI) – Via Giordano Bruno 21 is Alessio Balsini: dpo@well-fare.cloud.
4. Purposes of processing
WELL-FARE develops and manages the HQVillage platform accessible from mobile devices, such as smartphones, tablets, but also from personal PCs and any other device compatible with web browsing. The use of the platform takes place exclusively through the link www.hqvillage.com. WELL-FARE intends to offer its Customers/Users a communication service between Users and access to the Community/Network of Users and businesses.
The HQVillage platform has within it various features (also called “Services”) including, for example, selection of HQVillage destinations, properties dedicated to smartworkers and digital nomads, territorial self-screening services for Public Administration, self-screening services for Hosts, services for HR and Welfare Managers of Companies, promotion of services of third Partners of the HQVillage project.
The data you provide will be used for the purpose and for the purpose of making these services available, as well as specifically for the following activities:
1. a) execution, fulfilment, management and protection of the contract;
2. b) internal statistical analysis;
3. c) marketing activities through the sending of promotional and advertising material regarding products or services;
5. PERSONAL INFORMATION WE COLLECT
5.1 Information necessary for the use of the HQVillage Platform.
We collect personal information about you when you use the HQVillage Platform. Without this information, we may not be able to provide you with all the services you request. This information includes:
– Contact Information, Account, Profile Information. Such as your first name, last name, phone number, postal address, email address, date of birth and profile picture, some of which will depend on the features you use.
– Information about your job and qualifications. Such as job category, job sector, education, languages spoken, some of which will depend on the features you use.
– Information about personal and family needs. Such as experiential needs, who you travel with, quantitative data of how many travel companions you will have, age ranges of your travel companions, some of which will depend on the functionalities you use.
– Identity verification and payment details. Such as a photo of your ID (if permitted by applicable law), your ID number or other verification information, bank account or payment account details.
5.2 Optional information you may provide to us.
You may choose to provide us with additional personal information. This information may include:
– Additional profile information. Such as gender, preferred languages, city and a personal description. As indicated in your Account settings, some of this data is part of your public profile page and will be visible to others.
– Other information. For example, when you fill out a form, update or add information to your account, respond to surveys, post content in community forums, participate in promotions, communicate with our customer service staff and other Members, or share your experience with us. This may include health information if you choose to share it with us.
5.3 Information we automatically collect from your use of the HQVillage Platform and Payment Services.
When you use the HQVillage Platform and Payment Services, we automatically collect personal information. This information may include:
– Geolocation information. Such as the precise or approximate location determined by your IP address or the GPS on your mobile device, depending on your settings.
– Usage information. Such as the pages or content you view, your searches of Listings, bookings made and other actions taken on the HQVillage Platform.
– Log data and device information. Such as information about how you used the HQVillage Platform (including links to third-party applications you clicked on), IP address, date and time of access, hardware and software information, device information, device event information, unique identifiers, crash data, cookies, and the pages you viewed before or after using the HQVillage Platform. We may collect this information even if you have not created a HQVillage account or logged in.
– Cookies and similar technologies as described in our “Cookie Policy” Section.
– Payment Transaction Data. Such as payment instruments used, date and time, amounts paid, payment instrument expiry and billing address, email address linked to PayPal account, IBAN, your address and other transaction details.
5.4 Personal information we collect from third parties.
We collect personal information from other sources, such as:
– Third Party Services. If you log in, connect or access the HQVillage Platform with a third-party service (e.g. Google, Facebook, WeChat), you are instructing such tool to send us information such as, for example, registration data, friends list and profile information for which the data controller is such service or as authorised by you through the privacy settings of such service.
– General Information. For Members in the United States, to the extent permitted by applicable law, we may obtain information from public records regarding prior criminal convictions or sex offender registrations. For Members outside the United States, to the extent permitted by applicable law, and with your consent where required, we may obtain the local version of police checks, criminal records or registered sex offenders. We may use your information, including your full name and date of birth, to obtain such reports.
– Invitations to Use Company Products and Account Management. Organizations that use our Company Products may submit personal information to facilitate account management and invitations to use Company Products.
– Invitees and Companions. If you are invited to the HQVillage Platform as a travel companion, the person who invited you may send personal information about you such as your email address or other contact information.
– Other Sources. To the extent permitted by applicable law, we may receive additional information about you, including, for example, references, demographic data or information that helps detect fraud and security issues, from third-party service providers and/or partners and combine it with the information we hold about you. For example, we may receive background check results or fraud alerts from identity verification service providers for use in our fraud prevention and risk assessment efforts. We may receive information about you and your activities on or off the HQVillage Platform or about your experiences and interactions from our partners. We may receive health information, including but not limited to health information relating to contagious diseases.
6. COME UTILIZZIAMO I DATI CHE RACCOGLIAMO
6.1 Fornire, migliorare e sviluppare la Piattaforma HQVillage. Utilizziamo le informazioni personali per:
• Consentirti di accedere alla Piattaforma HQVillage ed effettuare e ricevere pagamenti.
• Consentirti di comunicare con altri Membri.
• Eseguire analisi, debug e condurre ricerche.
• Fornire assistenza clienti.
• Inviare messaggi, aggiornamenti, avvisi di protezione e notifiche di account.
• Se ci fornisci le informazioni dei tuoi contatti come i tuoi amici o i tuoi compagni di viaggio, possiamo trattare tali informazioni: (i) per facilitare l’invio di inviti ad altri utenti, (ii) per condividere i dettagli del tuo viaggio e facilitare la pianificazione del viaggio, (iii) per il rilevamento e la prevenzione delle frodi e (iv) per facilitare l’invio delle tue richieste o per qualsiasi altro scopo da te autorizzato.
• personalizzare e creare un’esperienza su misura, in base alle tue interazioni con la Piattaforma HQVillage, la tua cronologia di ricerca e di prenotazione, le tue informazioni e preferenze del profilo e altri contenuti che invii.
• Consentire l’utilizzo dei nostri prodotti aziendali.
6.2 Creare e mantenere un ambiente affidabile e più sicuro. Utilizziamo le informazioni personali per:
• Rilevare e prevenire frodi, spam, abusi, incidenti di sicurezza e di protezione e altre attività dannose.
• Studiare e contrastare le discriminazioni coerentemente con la nostra politica antidiscriminatoria.
• Svolgere indagini di sicurezza e valutazioni dei rischi.
• Verificare o autenticare le informazioni da te fornite.
• Effettuare controlli incrociati con banche dati e altre fonti di informazione, compresi controlli sui precedenti personali o controlli di polizia.
• Adempiere ai nostri obblighi legali, proteggere la salute e il benessere dei nostri Ospiti, Host, dipendenti degli Host e membri del pubblico.
• Risolvere le controversie con i nostri Membri.
• Far rispettare i nostri accordi con terze parti.
• Rispettare la legge, riscontrare le richieste di autorità pubbliche, prevenire i danni e proteggere i nostri diritti.
• Far rispettare i nostri “Termini” e le altre politiche.
• In connessione con le attività sopra descritte, potremmo eseguire profilazioni basate sulle tue interazioni con la Piattaforma HQVillage, sui dati del tuo profilo, su altri contenuti che invii a HQVillage e su informazioni ottenute da terzi. In casi limitati, processi automatici possono limitare o sospendere l’accesso alla Piattaforma HQVillage qualora tali processi rilevassero attività potenzialmente rischiose per la sicurezza di HQVillage, della nostra comunità o di terze parti. Se intendi contestare la decisione basata sul processo automatizzato, ti invitiamo a contattarci tramite la sezione “Informazioni di Contatto” di seguito.
6. HOW WE USE THE DATA WE COLLECT
6.1 Providing, improving and developing the HQVillage Platform. We use personal information to:
– Allow you to access the HQVillage Platform and make and receive payments.
– Allow you to communicate with other Members.
– Perform analysis, debugging and research.
– Provide customer support.
– Send you messages, updates, security alerts and account notifications.
– If you provide us with contact information such as your friends or travel companions, we may process such information: (i) to facilitate sending invitations to other users, (ii) to share your trip details and facilitate trip planning, (iii) for fraud detection and prevention, and (iv) to facilitate sending your requests or for any other purpose you authorize.
– customize and create a tailored experience based on your interactions with the HQVillage Platform, your search and booking history, your profile information and preferences, and other content you submit.
– Allow you to use our corporate products.
6.2 Create and maintain a reliable and safer environment. We use personal information to:
– Detect and prevent fraud, spam, abuse, security and safety incidents and other malicious activity.
– Investigate and combat discrimination in line with our anti-discrimination policy.
– Carry out security investigations and risk assessments.
– Verify or authenticate the information you provide.
– Cross-check databases and other sources of information, including background checks or police checks.
– Fulfill our legal obligations and protect the health and welfare of our Guests, Hosts, Hosts’ employees and members of the public.
– Resolve disputes with our Members.
– Enforce our agreements with third parties.
– Comply with the law, respond to requests from public authorities, prevent harm and protect our rights.
– Enforce our Terms and other policies.
– In connection with the activities described above, we may perform profiling based on your interactions with the HQVillage Platform, your profile data, other content you submit to HQVillage, and information obtained from third parties. In limited cases, automatic processes may limit or suspend your access to the HQVillage Platform if these processes detect activities that could potentially risk the security of HQVillage, our community or third parties. If you wish to contest the decision based on the automated process, please contact us via the “Contact Information” section below.
6.3 Provide, personalise, measure and improve our advertising and marketing. We may use your personal information to:
– Send you promotional messages, marketing information, advertising and other information that may be of interest to you based on your preferences, and social media advertising via social media platforms.
– Customise, measure and improve our advertising.
– Administer invitation programs, prizes, surveys, sweepstakes, contests or other promotional activities or events sponsored or administered by HQVillage or its third-party partners.
– Analyse your characteristics and preferences in order to send you promotional messages, marketing information, advertising and other information that we think may be of interest to you.
– Invite you to relevant events and opportunities.
6.4 Provide payment services. Personal information is used to enable or authorise third parties to use the Payment Services:
– Detect and prevent money laundering activities, fraud, abuse, security incidents.
– Conduct security investigations and risk assessments.
– Comply with legal obligations (such as anti-money laundering regulations).
– Ensure the application of the “Payment Terms” and other payment policies.
– With your consent, send you promotional messages, marketing information, advertising and other information which may be of interest to you based on your preferences.
– Provide and improve the Payment Services.
7. CONDIVISIONE E DIVULGAZIONE
7.1 Condivisione con il tuo consenso o secondo le tue indicazioni.
Laddove tu abbia dato il tuo consenso, condividiamo i tuoi dati come descritto nel momento in cui abbiamo ottenuto il tuo consenso, ad esempio quando autorizzi un’applicazione o un sito web di terze parti ad accedere al tuo account HQVillage o quando partecipi ad attività promozionali condotte da partner di HQVillage o terze parti.
Laddove consentito ai sensi della legge applicabile, potremmo utilizzare alcune informazioni su di te, come il tuo indirizzo email, renderle anonime e condividerle con piattaforme di social media, per generare lead, guidare il traffico verso HQVillage o promuovere in altro modo i nostri prodotti e servizi.
7.2 Condivisione tra membri.
Per facilitare le prenotazioni o altre interazioni tra i Membri, potremmo dover condividere alcune informazioni quali:
• Quando viene effettuata una richiesta di prenotazione o viene inviata una contestazione, alcune informazioni potrebbero essere condivise tra Ospiti e Host, come ad esempio profilo, nome, nomi di eventuali Ospiti aggiuntivi, cronologia delle cancellazioni, informazioni sulle recensioni, età dell’ospite (se non vietato dalla legge applicabile), esito della contestazione (se applicabile) e altre informazioni che hai scelto di condividere e inviare. Quando una prenotazione è confermata, vengono divulgate informazioni aggiuntive per facilitare il coordinamento del viaggio: fra queste, il tuo numero di telefono e la foto di profilo. Quando in qualità di Host hai una prenotazione confermata, alcuni dati verranno condivisi con l’Ospite (e gli eventuali Ospiti aggiuntivi invitati, se pertinente) per gestire la prenotazione, tra cui, ad esempio, il tuo profilo, nome e cognome, numero di telefono e indirizzo dell’Alloggio.
• Quando, in qualità di Host, inviti un altro Membro a diventare un Co-Host, autorizzi il Co-Host ad accedere e aggiornare i tuoi dati e Contenuti dei Membri, ivi comprese, a titolo esemplificativo e non esaustivo, alcune informazioni quali il tuo nome e cognome, numero di telefono, indirizzo dell’Alloggio, calendario, informazioni dell’Annuncio, foto dell’Annuncio e indirizzo email.
• Quando, in qualità di Ospite, inviti altri Ospiti ad una prenotazione, il tuo nome e cognome, le date di viaggio, il nome dell’Host, i dettagli dell’Annuncio, l’indirizzo dell’Alloggio e altre informazioni rilevanti saranno condivise con ogni Ospite aggiuntivo.
7. SHARING AND DISCLOSURE
7.1 Sharing with your consent or as you instruct.
Where you have given your consent, we will share your information as described at the time we obtained your consent, such as when you authorize a third party application or website to access your HQVillage account or when you participate in promotional activities conducted by HQVillage partners or third parties.
Where permitted under applicable law, we may use certain information about you, such as your email address, anonymise it and share it with social media platforms, to generate leads, drive traffic to HQVillage or otherwise promote our products and services.
7.2 Sharing Between Members.
To facilitate bookings or other interactions between Members, we may need to share certain information such as:
– When a reservation request is made or a dispute is sent, certain information may be shared between Guests and Hosts, such as profile, name, names of any additional Guests, cancellation history, review information, age of Guest (unless prohibited by applicable law), outcome of dispute (if applicable), and other information that you have chosen to share and send. When a reservation is confirmed, additional information is disclosed to facilitate travel coordination, including your phone number and profile photo. When you as a Host have a confirmed booking, certain information will be shared with the Guest (and any additional invited Guests, if applicable) to manage the booking, including, for example, your profile, full name, phone number and Accommodation address.
– When, as a Host, you invite another Member to become a Co-Host, you authorize the Co-Host to access and update your information and Member Content, including, without limitation, certain information such as your first and last name, phone number, Accommodation address, calendar, Listing information, Listing photo and email address.
– When you, as a Guest, invite other Guests to a booking, your first and last name, travel dates, Host name, Listing details, Accommodation address and other relevant information will be shared with each additional Guest.
7.3 Information you publish in Profiles, Announcements and other public information.
You can make certain information visible to the public, such as:
– Your public profile page, which includes your profile picture, name, description and city.
– Your Listing pages, which include information such as a description of the approximate or precise location of the Listing or Experience, calendar availability, profile photo, aggregate demand information (e.g., number of views in a given period), and any additional information you choose to share.
– Reviews, ratings and other public feedback.
– Content in a community or discussion forum, blog or social media post.
We may display parts of your public profile and other Content that you make publicly available, such as details of the Advertisement on third party sites, platforms and apps.
The data you publicly share on the HQVillage Platform may be indexed by third party search engines. In some cases, you can disable (opt-out) from this feature in your Account settings.
7.4 Host Service Providers.
Hosts may use third party services to assist them in managing or providing their services, such as cleaning or access service providers. Hosts may use features available on the HQVillage Platform to share information about the Guest (e.g., check-in and check-out dates, Guest’s name and phone number) with such third party service providers.
7.5 Compliance with the law, responding to requests from public authorities, preventing harm and protecting our rights.
We may disclose your information to courts, law enforcement or governmental or public authorities, to tax authorities, or to authorized third parties, if and to the extent that we are required or authorized 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 made against HQVillage, (iii) to comply with a valid legal request relating to a criminal investigation or alleged or alleged illegal activity or any other activity that may expose us, yourself or any of our other users to liability under laws or regulations, (iv) to administer and enforce our agreements with Members, (v) to protect the rights, property or personal safety of HQVillage, its employees, its Members or the general public. For example, if permitted by the foregoing circumstances, a Host’s tax information may be shared with tax or other governmental agencies.
Where appropriate, we may inform Members of law enforcement requests, unless: (i) providing such information is prohibited by applicable legal process, pursuant to an order received from a court, or pursuant to law, or (ii) we believe that notice is unnecessary or ineffective, creates a risk of injury or physical harm to an individual or group of individuals, or creates or increases a risk of fraud against HQVillage, its Members, or exposes HQVillage to charges of obstruction of justice.
In countries where HQVillage facilitates the collection and remittance of Taxes, where permitted by applicable law, we may disclose information regarding Hosts and Guests relating to their transactions, bookings, Accommodations and Accommodation Taxes to the appropriate tax authorities; such data may include the name of the Host or Guest, Ad addresses, transaction dates and amounts, tax identification numbers, the amount of Taxes received (or owed) by Hosts from Guests and contact information.
In countries where HQVillage facilitates or requires Host registration, notification, permission or licensing with a local governmental authority through HQVillage in accordance with such local law, we may share information about participating Hosts – such as the Host’s first name, last name and contact information, Accommodation address, tax identification numbers, Listing details and number of nights booked – with the designated authority, both during such process and at periodic intervals.
7.6 Programs with staff and owners.
We may share Hosts’ and Guests’ personal information, such as reservation information, and information regarding compliance with applicable laws, such as short-term rental laws, with owners, management companies and/or landlords of accommodations (the “Accommodation Staff”) in order to facilitate scheduling with the Accommodation Staff. For example, guest booking and personal information, including guest contact information, may be shared with the Accommodation Staff of the building, complex or community in which a Host lives and/or accommodation is located in order to facilitate hosting services, compliance with applicable law, security, billing and other services.
7.7 Host Data Provided to Business Customers.
If a reservation is indicated as being made for business purposes by a Company and (1) it is made by a Host affiliated with a Company, (2) the Company is registered with HQVillage, we may disclose information related to the reservation to the Company, such as, for example, the name of the Host, the address of the Accommodation, the dates of the reservation, the details of the Accommodation, etc., to the extent necessary for the proper performance of the contract between HQVillage and the Company and the provision of services. At the request of the Company or Guest we may also share such information with third parties engaged by the Company to provide support services.
7.8 Service Providers.
We share personal information with affiliated and unaffiliated service providers to help us operate our business, including service providers who help us: (i) verify your identity or identification documents, (ii) verify information by checking it against public databases, (iii) conduct criminal background checks, for fraud prevention and risk assessment (iv) provide product development, maintenance and technical support services, (v) enable delivery of HQVillage Services through third party platforms and software (e.g., through integration with our APIs), or (vi) provide customer support, advertising or payment services, or (vii) process, manage or estimate claims or other claims of a similar nature, or (viii) facilitate non-profit and charitable activities consistent with HQVillage’s mission. These vendors are contractually bound to protect your personal information that they have access to in order to carry out these activities.
7.9 Business Transfers.
If HQVillage undertakes or is involved in any merger, acquisition, reorganization, business sale or bankruptcy or insolvency proceeding, we may sell, transfer or share some or all of our assets, including your information, in connection with or as a result of such transaction (e.g., during due diligence). In this case, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.
7.10 Group companies.
To enable us or assist us in providing, integrating, promoting and improving the HQVillage Platform, Payment Services and the services of our affiliates, we may share personal information within our corporate group with companies that are related by common ownership or control.
8. OTHER IMPORTANT INFORMATION
8.1 Analysis of your communications.
We may review, scan or analyse your communications on the HQVillage Platform for the reasons described in the “How We Use the Data We Collect” section of this Policy, including for purposes of fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, analysis, enforcement of our “Terms” and customer service. For example, as part of our fraud prevention activities, we may scan and analyse messages to hide contact information and references to other sites. In some cases, we may also scan, review or analyze messages to debug, improve and expand product offerings. We will use automated methods when reasonably possible. However, from time to time we may need to manually review certain communications, including, for example, for anti-fraud and customer service investigations or to evaluate and improve the functionality of such automated tools. We will not review, observe or analyse your messaging communications to send you third party marketing messages and we will not sell reviews or analysis of such communications.
8.2 Linking with Third Party Accounts.
You may link your HQVillage account to certain third party services such as social networks. Your contacts on such third party services are referred to as “Friends”. When you request data sharing by creating this link:
– some of the information you provide to us by linking your accounts may be published on your public profile;
– your activities on the HQVillage Platform may be viewed by your Friends on the HQVillage Platform and/or on such third-party site;
– a link to your public profile on such third-party service may be included in your public profile on HQVillage;
– other HQVillage users may be able to view any Friends you have in common with them, or the fact that you are a Friend of their Friends, where applicable;
– other HQVillage users may be able to view the schools, home town or other groups you have in common with them as reported in your connected social networking services;
– the information you provide to us through the linking of your accounts may be stored, processed and transmitted for the purposes of fraud prevention and risk assessment;
– the publication and display of the information provided to the HQVillage Platform via this link is subject to any of your settings and permissions on the HQVillage Platform and the third-party service.
8.3 Third Party Partners and Integrations.
Portions of HQVillage may link to third party services, not owned or controlled by HQVillage, such as Google Maps/Earth. Use of these services is subject to the privacy policy of those providers, such as Google Maps/Earth’s Additional Terms of Use, Google’s Privacy Policy (see this page for more information on how Google uses information), and Citi’s Privacy Policy. HQVillage does not own or control such third parties and when you interact with them you are providing them with your information.
9. YOUR RIGHTS
In accordance with applicable law, you may exercise any of the rights described in this section. For more information about data subject requests and how to submit them, please write to dpo@well-fare.cloud. Please note that we may ask you to verify your identity and your request before taking any further action on it.
At any time, you may exercise, pursuant to Article 7 of Legislative Decree 196/2003 and Articles 15 to 22 of EU Regulation No. 2016/679, the right to:
1. a) request confirmation of the existence or otherwise of your personal data;
2. b) obtain information about the purposes of the processing, the categories of personal data, the recipients or categories of recipients to whom the personal data have been or will be communicated and, when possible, the storage period;
3. c) obtain the rectification and erasure of data;
4. d) obtain the limitation of the processing;
5. e) obtain the portability of the data, i.e. receive them from a data controller, in a structured, commonly used and machine-readable format, and transmit them to another data controller without hindrance;
6. f) to object to the processing at any time and also in case of processing for direct marketing purposes;
7. g) to object to automated decision-making relating to natural persons, including profiling, except as provided for in Art. 9 of this policy;
8. h) request from the data controller access to and rectification or erasure of personal data or restriction of the processing of personal data concerning him/her, or to object to the processing of such data, in addition to the right to data portability
9. i) withdraw consent at any time without affecting the lawfulness of the processing based on the consent given before the withdrawal;
10. j) lodge a complaint with a supervisory authority.
You can exercise your rights by sending a written request to the company WELL-FARE S.r.l. with registered office in Pontedera (PI) – Via Giordano Bruno 21, or by email to the Data Controller’s address luca.piras@well-fare.cloud or to dpo@well-fare.cloud .
9.1 Data management.
You can access and update some of your personal information from your Account settings. If you have linked your HQVillage Account to a third party application, such as Facebook or Google, you can change the settings and disconnect from that service from your Account settings. You are responsible for updating your personal information.
9.2 Data portability and access.
In some countries, applicable law may give you the right to request copies of your personal information or information about how we handle your personal information, to request copies of personal information that you have provided to us in a structured, commonly used and electronically readable format, and/or to require us to transfer such information to another service provider (where technically feasible).
9.3 Data Deletion.
In some countries, you may request that we delete your personal information. Please note that if you decide to request deletion of your personal information:
– We may retain your personal information as necessary for our legitimate business interests, such as preventing money laundering, detecting and preventing fraud and improving security. For example, if we suspend an HQVillage Account for fraud or security reasons, we may retain certain information from that account to prevent the same Member from opening a new HQVillage Account in the future.
– We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, HQVillage may retain your information for tax, legal reporting and inspection obligations.
– Information that you have shared with others (such as Ad reviews, forum posts) may continue to be publicly visible on HQVillage, even after you delete your HQVillage Account. However, attribution to your person of such information will be removed. Some copies of your information (e.g., log logs) will remain in our database, but are disassociated from personally identifiable information.
– Because we take measures against accidental or intentional loss or destruction of data, residual copies of your personal information may not be removed from our backup systems for a limited period of time.
10. SECURITY
Although no organisation can guarantee absolute security, we continually improve and update administrative, technical and physical security measures to protect your information from unauthorised access, loss, deletion or alteration.
11. CHANGES TO THIS PRIVACY POLICY
We reserve the right to change this Privacy Policy at any time in accordance with applicable law. If we do so, we will post the new Privacy Policy and update the “Last Updated” date at the top of it. If we make material changes, we will also notify you by email at least thirty (30) days prior to the effective date of the changes. If you do not agree with the updated Privacy Policy, you may delete your Account. If you do not delete your Account before the effective date of the updated Privacy Policy, your continued access to or use of the HQVillage Platform will be subject to the amended Privacy Policy.
12. HQVILLAGE CONTACT INFORMATION AND RESPONSIBLE PARTIES
If you have any questions or complaints about this Privacy Policy or HQVillage’s processing of your personal data (i) please contact WELL-FARE S.R.L., Legal Privacy, Via Giordano Bruno 21, 56025 – Pontedera (PI) – Italy (ii) for payment-related matters, please use the contact information provided on the “Terms” page and (iii) if you reside outside the United States, please use the contact information of your data controller provided in Section 3. Data Protection Officer (DPO).
Business Customers and Collaborators
This page supplements HQVillage’s Privacy Policy for Corporate Customers as described below.
1. INFORMATION PROVIDED TO CORPORATE CUSTOMERS
If you link your HQVillage Account to the HQVillage Account of a company or other organization (a “Company”), for example by adding your professional email address, or you have a reservation made by a third party (such as a prospective employer or other entity) or through a Company-related coupon (such as a coupon to pay for accommodations for a corporate event, such as onboarding, orientation, meetings, etc.) through one of our corporate products. ) through one of our corporate products, that Company will have access to your name, contact information, permissions and roles, booking information and other information related to your business travel.
2. GUEST INFORMATION PROVIDED TO HQVILLAGE CUSTOMERS
If you have linked your HQVillage Account to a Company or delegated a party to book travel for you and appear on a reservation, we may disclose reservation information to the Company to the extent necessary for the proper performance of the contract between HQVillage and the Company. Typically, such data includes booking information such as your name, dates of booking, number of guests, prices, Listing details, address of the Accommodation and other related information. At your or your Company’s request, we may also share such information in order to assist service providers engaged by the Company. In the event of a dispute or emergency involving the booking of a business stay, HQVillage may also share additional relevant information to resolve the issue quickly and securely.