New version of privacy policy

General provisions

1. To preserve the privacy rights of Users of the animalhotels.com Website and Application and to comply with the provisions of the law, animalhotels.com provides its Users with the present Privacy Policy, which includes information on the manner in which Users' personal data are processed and secured.
2. Animalhotels.com processes personal data in compliance with applicable legal regulations, including Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR), the Act of 18 July 2002 on Providing Services by Electronic Means, and – where applicable – local data protection laws outside the European Economic Area, such as the UK GDPR (United Kingdom), CCPA/CPRA (United States – California), PIPEDA (Canada), LGPD (Brazil), APPI (Japan), and POPIA (South Africa).
3. Animalhotels.com has implemented the following rules:
   • data shall be collected for specified, explicit and legitimate purposes and not further processed by animalhotels.com in a way incompatible with those purposes ("purpose limitation");
   • before collecting data, the data subject is always informed in a clear and transparent manner of the purposes for which the data are processed ("lawfulness, fairness and transparency");
   • only data which are adequate and limited to what is necessary to fulfil the purposes for which they are processed are collected ("data minimisation");
   • data shall be accurate and updated if necessary ("accuracy");
   • data shall be kept in a form which permits identification of the data subject for no longer than is necessary for the purposes for which they are processed ("storage limitation");
   • data are processed in a way that ensures appropriate security, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage by means of appropriate technical or organisational measures ("integrity and confidentiality").
4. Before using the animalhotels.com Website and/or the Application or creating an account, the User should read the Privacy Policy.

Definitions

Policy – the present Privacy Policy.

Animalhotels.com – a limited liability company (sp. z o.o.) with its registered office in Łódź (ul. Lutomierska 52/2, 91-004 Łódź), entered into the Register of Entrepreneurs kept by the District Court for Łódź-Śródmieście in Łódź, XX Commercial Division of the National Court Register under KRS number 0000934860, REGON (National Business Registry Number) 520527265, NIP (Tax Identification Number) 7252314345.

Application – the animalhotels.com mobile application for Android and IOS systems made available to Users.

User – a natural person whose personal data is processed by animalhotels.com in connection with the use of the animalhotels.com Website and/or the Application.

Personal data – any information about an identified or identifiable natural person ("data subject").

GDPR (RODO) – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC.

Subscription – a paid service provided by Animalhotels.com to a Caretaker, as defined in the Terms and Conditions.

Animal Service – paid services involving the care of an animal/animals provided by a Caretaker to an Owner.

Enquiry – an Owner's submission concerning the Animal Service they are looking for, as defined in the Terms and Conditions.

Website – the animalhotels.com website accessible to Users at https://animalhotels.com.

I. Data collection and processing

1. The controller of personal data provided by the User while using the Website and/or the Application is Animalhotels.com.
2. As a result of using the Website and/or the Application, Animalhotels.com may process in particular the following personal data: name and surname, address, phone numbers, email addresses, tax identification number, date of birth, likeness, message content, review content, bank account number, payment and Subscription data, information about animals together with their photos, video recordings (Reels) and the approximate location of an Enquiry.
3. Animalhotels.com ensures that its Users can use the Website and/or the Application anonymously, however, to obtain full access to the services offered through the Website and/or the Application, it is advisable to register by completing a registration form. The provision of data by the User is voluntary, although the provision of certain data is necessary to set up an account or use certain features of the Website and/or the Application, e.g. to receive a newsletter. If the data are collected to comply with an obligation stipulated by law, the provision of data is mandatory.
4. After registration and logging into one's account, the User may provide additional personal data which facilitates the use of services.

II. Purpose and legal basis for data processing

Provision of services

Animalhotels.com processes personal data to enable and manage Animal Services, as well as other services provided through the Website and/or the Application, including educational services (e.g., courses or training sessions). The processing of data is necessary for the provision of these services and includes, among other things, sending the User information related to bookings or orders, such as confirmations, reminders, updates, and, where applicable, proof of purchase and/or payment.

This includes in particular:

• concluding and settling Subscriptions for Caretakers, including data on the selected plan, billing period, promotions and payment history;
• handling claims under Animalhotels Care, including the description of the incident, documentation, attachments and the bank account number for paying out the benefit;
• running the Loyalty Programme for Owners, including awarding points and issuing rewards;
• publishing Caretakers' Reels and counting their views and likes;
• at the Caretaker's request, making the data of their Bookings, including the Owner's name, surname and contact details and information about the animal, available to them in the Pawlendar calendar, a tool operated by Animalhotels.com.

Personal data is processed for the provision of services in compliance with applicable data protection laws:

• within the European Union, the legal basis for processing personal data is Article 6(1)(b) GDPR (acceptance of the Terms and Conditions of the Website and/or Application);
• outside the European Union, processing is based on local laws ensuring protection equivalent to the GDPR.

Sharing Enquiries with Caretakers

To enable the Owner to find a Caretaker, Animalhotels.com presents the Enquiry to Caretakers operating within a radius of up to 50 km, as well as via an Enquiry preview link available without logging in. The following are presented: the Owner's first name, approximate location (shifted by several hundred metres), dates, type of service, selected amenities, and information about the animal and its photo. The Owner's surname, phone number, email address and exact address are not presented.

• within the European Union, the legal basis for processing personal data is Article 6(1)(b) GDPR (performance of a contract to which the Owner is a party);
• outside the European Union, processing is based on local laws ensuring protection equivalent to the GDPR.

Marketing communication

Operational communication related to the provision of Animal Services

Animalhotels.com provides the User with information, instructions and guidance necessary to facilitate the provision of Animal Services. Personal data will be processed for the duration necessary to perform the agreement, and after its termination for the period required by archiving regulations and laws concerning the enforcement of claims. The information may include, among other things, instructions on using the Website and/or the Application, guidance on the provision of Animal Services and operational messages that improve service delivery.

Direct marketing communication (newsletter, updates, offers)

Animalhotels.com sends the User newsletters and marketing information regarding Services, new features and updates related to the Website and/or the Application. Personal data is processed on the basis of the legitimate interest of the Controller in conducting direct marketing. Data will be processed until the User withdraws consent or objects to the processing of personal data for direct marketing purposes. The User may withdraw their consent at any time via their Account settings or using the unsubscribe link provided in each marketing message.

Personalised advertising

Animalhotels.com shares personal data with advertising partners (in particular Meta Platforms Ireland Limited, Google Ireland Limited and Microsoft Ireland Operations Limited) for marketing activities involving custom audience groups and ad personalisation.

Personal data (e.g., email address, phone number or online identifiers) is processed on the basis of the User's consent. Before sharing with advertising partners, data may be hashed or pseudonymised, limiting the ability of external parties to directly identify the User. This data is used solely to match existing User profiles in advertising systems and to display personalised advertisements to them, in accordance with the rules applicable to the given provider.

Data is processed until the consent is withdrawn or the data becomes obsolete. The User may withdraw consent for data processing for advertising purposes at any time via their Account settings, cookie settings, advertising settings on external platforms (e.g., Meta, Google) or by contacting Animalhotels.com.

Transfers of personal data to advertising partners located outside the European Economic Area may involve a transfer to a third country; in such cases, appropriate safeguards are applied, including standard contractual clauses or adequacy decisions in accordance with the GDPR.

Personal data is processed for the provision of the above services in compliance with applicable data protection laws:

• within the European Union, the legal basis for processing personal data is:
  • for operational communication - Article 6(1)(b) GDPR (performance of a contract),
  • for direct marketing communication - Article 6(1)(f) GDPR (legitimate interests of the Controller) and, with respect to sending information electronically, Article 10 of the Act on Providing Services by Electronic Means and Article 172 of the Telecommunications Law (User consent),
  • for personalised advertising - Article 6(1)(a) GDPR (User consent);
• outside the European Union, processing is based on local laws ensuring protection equivalent to the GDPR.

Performance of legal obligations by animalhotels.com

Animalhotels.com processes data when it is necessary for the performance of legal obligations. In certain cases, it may be necessary to reuse data to:

• handle and resolve legal claims and disputes,
• address potential regulatory investigations,
• enforce the terms of the Website in relation to online bookings,
• comply with lawful requests from law enforcement authorities,
• ensure compliance with laws and regulations applicable to Animalhotels.com.

Animalhotels.com may be required to collect and disclose the personal data of Users providing Animal Services to tax authorities, in accordance with applicable legal provisions, including the DAC7 Directive and national regulations implementing this Directive in the European Union. This may include identity details, contact information, tax identification number, payment details and income information.

Personal data is processed for the provision of services in compliance with applicable data protection laws:

• within the European Union, the legal basis for processing personal data is Article 6(1)(c) GDPR (compliance with legal obligations of animalhotels.com);
• outside the European Union, processing is based on local laws ensuring protection equivalent to the GDPR.

Ensuring the security and operation of the Website and/or the Application

Animalhotels.com processes personal data if it is necessary to ensure the security of data processing on animalhotels.com and management of ICT systems. For this purpose, the login and registration forms are protected by Cloudflare Turnstile verification, which checks whether the form is being completed by a human.

Personal data is processed for the provision of services in compliance with applicable data protection laws:

• within the European Union, the legal basis for processing personal data is Article 6(1)(f) GDPR (legitimate interest of animalhotels.com - ensuring the operation of the Website and/or the Application and maintaining high service quality);
• outside the European Union, processing is based on local laws ensuring protection equivalent to the GDPR.

Communication between Users of the Website and/or the Application

Animalhotels.com collects the content of messages and information provided by the User using this feature.

Messages sent in the chat by Caretakers who do not have an active Subscription are automatically checked for proposals to settle Animal Services outside the Website and/or the Application. In such a case, the Caretaker receives an automatic warning visible only to them. The decision on any disqualification of an Offer is made by an Animalhotels.com employee after reviewing the conversation.

Personal data is processed for the provision of services in compliance with applicable data protection laws:

• within the European Union, the legal basis for processing personal data is Article 6(1)(b), (d) and (f) GDPR (legitimate interest of animalhotels.com and User protection - ensuring the operation of the Website and/or the Application, resolving possible incidents related to communication between Users and enforcing the settlement rules set out in the Terms and Conditions);
• outside the European Union, processing is based on local laws ensuring protection equivalent to the GDPR.

User reviews and ratings

Animalhotels.com processes data derived from reviews and ratings submitted by Users in accordance with the Terms and Conditions, for the purpose of monitoring the quality of the Animal Services, assessing User satisfaction, maintaining a high standard of communication between Users, and identifying and preventing undesirable behaviour. This data may also be used for the profiling of Caretakers to ensure a better match with the Owner's request. Caretakers may also leave reviews of Owners, covering an assessment of communication and the animal's behaviour; the Owner is notified when such a review is left, and reviews are visible to the Caretakers to whom the Owner presents Enquiries.

Personal data is processed for the provision of services in compliance with applicable data protection laws:

• within the European Union, the legal basis for processing personal data is Article 6(1)(b) and (f) GDPR (legitimate interest of animalhotels.com - ensuring the operation of the Website and/or the Application, maintaining high service quality and improving service quality);
• outside the European Union, processing is based on local laws ensuring protection equivalent to the GDPR.

Handling inquiries from Website and/or Application Users

Animalhotels.com processes personal data to handle complaints from Users related to the operation of the Website and/or the Application, contact the User or a third party using the Website and/or the Application and take appropriate explanatory or corrective actions, and clarify possible incidents related to User support and improve its quality.

Animalhotels.com erases the data arising in this context when their storage is no longer required or restricts their processing if there are statutory requirements for the retention of such data.

Personal data is processed for the provision of services in compliance with applicable data protection laws:

• within the European Union, the legal basis for processing personal data is Article 6(1)(c), Article 6(1)(b) and Article 6(1)(f) GDPR (legitimate interest of animalhotels.com - ensuring the operation of the Website and/or the Application, maintaining high service quality, improving service quality and resolving possible incidents related to User support);
• outside the European Union, processing is based on local laws ensuring protection equivalent to the GDPR.

Investigation or protection against possible claims

Personal data is processed for the provision of services in compliance with applicable data protection laws:

• within the European Union, the legal basis for processing personal data is Article 6(1)(f) GDPR (legitimate interest of animalhotels.com - protection against claims or pursuit of claims);
• outside the European Union, processing is based on local laws ensuring protection equivalent to the GDPR.

Newsletter

Animalhotels.com processes Users' personal data for the purpose of sending the Newsletter the User has subscribed to. The data processing and sending the newsletter require the User's consent.

Personal data is processed for the provision of services in compliance with applicable data protection laws:

• within the European Union, the legal basis for processing personal data is Article 6(1)(a) GDPR;
• outside the European Union, processing is based on local laws ensuring protection equivalent to the GDPR.

Promoting safe and trustworthy Services and fraud prevention

Animalhotels.com processes personal data to prevent fraud, detect illegal or unwanted activities, and ensure animal safety and trust on the Website and/or the Application. In justified cases, such as reported booking issues, the processing of data may include temporarily suspending a booking until the matter is clarified.

The scope of processed data includes, among other things, contact details, booking information (including cancelled bookings), location data, account details, reviews, browsing and communication data, and information submitted by the User or third parties.

Phone numbers associated with Accounts blocked for violating the Terms and Conditions may be stored even after the Account is deleted, solely to prevent re-registration, for a period of 5 years from the date the Account was blocked. A person who has been refused registration for this reason may challenge this by writing to [email protected].

Personal data is processed for the provision of services in compliance with applicable data protection laws:

• within the European Union, the legal basis for processing personal data is Article 6(1)(f) GDPR (legitimate interest of animalhotels.com - ensuring the operation of the Website and/or the Application and maintaining high service quality);
• outside the European Union, processing is based on local laws ensuring protection equivalent to the GDPR.

Service improvement

Personal data of Users of Animalhotels.com may be used for the following purposes:

• analytical purposes (analysing service performance, gaining a better understanding of how the services are used and, consequently, improving them);
• ensuring the safety of Users of the Website and/or the Application;
• preventing abuse of the Terms and Conditions and of the law;
• resolving technical issues;
• improving functionality and enhancing the quality of the Services.
• using artificial intelligence technologies and automated data processing systems. In addition to statistics regularly generated by Animalhotels.com for monitoring purposes, this data is also used for testing functionalities and resolving technical issues. This includes, among other things, analysing how the Website is used, measuring operational performance, identifying behavioural patterns and enhancing the functionality and services related to the Animal Service.

Animalhotels does not make decisions regarding Users based solely on automated processing of personal data, including profiling, that would produce legal effects concerning them or similarly significantly affect them, subject to the mechanisms arising from the Terms and Conditions: the order in which Caretakers receive Enquiries depends, among other things, on how quickly they responded to previous Enquiries, and failure to respond to an individual Enquiry within the set deadline results in the automatic deactivation of the Caretaker's Offers, which the Caretaker can reverse themselves in their Account. The Caretaker may challenge such an action by writing to [email protected]; the matter is reviewed by an Animalhotels.com employee.

The main purpose of data processing in this context is to analyse service performance, gain a better understanding of how the services are used, and, consequently, optimise and personalise the online platform and the application to make them more user-friendly and functional.

Personal data is processed for the provision of services in compliance with applicable data protection laws:

• within the European Union, the legal basis for processing personal data is Article 6(1)(f) GDPR (legitimate interest of animalhotels.com - ensuring the operation of the Website and/or the Application and maintaining high service quality);
• outside the European Union, processing is based on local laws ensuring protection equivalent to the GDPR.

The User has the right to object at any time to the processing of their personal data based on a legitimate interest (Article 21 GDPR).

III. Data retention period

1. Animalhotels.com stores Users' personal data only for the period necessary to fulfil the purposes for which it was collected. After this period, the data is erased or anonymised in such a way that it is not possible to determine the User's identity.
2. Personal data may be stored for a longer period if such obligation results from the provisions of the law or if it is necessary for animalhotels.com to defend against or pursue claims against Users.
3. Data processed based on consent are processed until the consent is withdrawn.

IV. User rights

1. Right to access personal data: upon the User's request, animalhotels.com will confirm which of the User's personal data it processes and provide the User with a copy of such data. Notwithstanding the above, the registered User has access to the personal data they have provided to animalhotels.com through the User account on the Website and/or Application.
2. Right to rectify personal data - if the User's personal data are incorrect or incomplete, the User may request animalhotels.com to rectify or complete their data. Notwithstanding the above, the registered User has the right to correct their personal data through the User account on the Website and/or Application.
3. Right to restrict the processing of personal data - the User may request a temporary suspension of the processing of their data in certain situations.
4. Right to erase personal data - in certain situations, the User may request the erasure of personal data processed by animalhotels.com.
5. Right to receive one's personal data in a structured, commonly used format and to have it transferred, when the processing is based on consent and when it is carried out by automated means.
6. Right to withdraw consent: to the extent that personal data are processed on the basis of consent, the User has the right to withdraw their consent at any time.
7. Right to object to the processing of personal data - the User may object to the processing of their personal data on the basis of a legitimate interest or for statistical purposes (due to their particular situation) or to the processing of data for direct marketing purposes.
8. In the event that a User believes the processing of their personal data violates the data protection laws of their country, they have the right to lodge a complaint with the competent data protection supervisory authority – in particular the authority of the European Union Member State of their habitual residence, place of work or place of the alleged infringement.

For Users from Poland, the competent authority is the President of the Personal Data Protection Office with its registered office in Warsaw. Further information on submitting complaints is available at: https://uodo.gov.pl/pl/83/155.

V. Profiling

The User's personal data processed for marketing purposes will be subject to automated decision-making processes, including profiling. This means that, based on the personal data held by animalhotels.com and information regarding the services purchased by the User or cookies stored on the User's device, animalhotels.com will make inferences concerning the User's preferences and interests, which may be used to build the User's marketing profile.

Profiling may also include tailoring the advertising content displayed to the User in the advertising systems of third parties, in particular Meta Platforms (Facebook, Instagram), Google and Microsoft.

VI. Cookies

1. Animalhotels.com uses cookies.
2. Cookies are IT data, in particular text files, which are stored on the Website User's terminal device and are intended for the use of animalhotels.com websites. Cookies usually contain the name of the website they come from, the time they are stored on the terminal device and a unique number.
3. The entity placing cookies on the User's terminal device and accessing them is the Website operator.
4. Cookies are used for the following purposes:
   • remembering User preferences regarding consent to cookies, which is carried out using CookieScriptConsent (https://cookie-script.com/legal/privacy-policy). The data storage period is 1 month;
   • maintaining the User's session (after logging in), thanks to which the User does not have to re-enter their login and password on each sub-page of the Website. The data storage period is 1 year and 1 month;
   • statistical purposes, which are carried out using analytics tools such as Google Analytics and Hotjar. These tools may process information on how the Website is used, including online identifiers, device data and information about activity on the site. This data may be processed in anonymised or pseudonymised form in accordance with the processing rules set by the tool providers. Detailed information is available at: https://policies.google.com/privacy; https://www.hotjar.com/privacy/;
   • marketing purposes, which are carried out using third-party advertising tools, in particular Meta Ads Pixel (Meta Platforms Ireland Limited), Google Ads (Google Ireland Limited) and Microsoft Bing Ads / Microsoft Clarity (Microsoft Ireland Operations Limited). These tools may process information about the User's activity on the site, enable the creation of audience groups and ad personalisation. Data may be processed in anonymised or pseudonymised form based on the rules set by the given provider.

   When Meta Ads Pixel is used, information about the User's activity on the Website (such as visited sub-pages or actions taken) is collected for analytical and marketing purposes. This information may constitute personal data within the meaning of data protection laws and is processed on the basis of the User's consent to marketing cookies. Meta Platforms may combine this information with data it holds in accordance with its own privacy policy. The providers' policies are available at: https://www.facebook.com/privacy/policy; https://policies.google.com/privacy; https://www.microsoft.com/privacy/privacystatement.

5. Animalhotels.com uses two main types of cookies: "session cookies" and "persistent cookies". "Session cookies" are temporary files that are stored on the User's terminal device until the User logs out, leaves the website or switches off the software (web browser). "Persistent cookies" are stored on the User's terminal device for the time specified in the parameters of the cookies or until they are deleted by the User.
6. Animalhotels.com also uses Local Storage objects in the HTML5 standard, which are stored on the User's computer. These objects store the necessary data regardless of the browser used by the User and do not have an automatically set expiry date. To prevent the use of HTML5 storage objects, the browser must be used in private mode.
7. Web browsing software (Internet browser) usually allows cookies to be stored on the User's terminal device by default. Website Users can change their settings in this respect. The web browser makes it possible to delete cookies. It is also possible to automatically block cookies. For details, refer to the help section or documentation of the web browser.
8. Restrictions on the use of cookies may affect some of the features available on the animalhotels.com websites.
9. If the User does not wish to receive cookies, they can change their browser settings. Animalhotels.com stipulates that disabling cookies necessary for the authentication processes, security or maintaining user preferences may hinder and, in extreme cases, make it impossible to use the websites.
10. The cookie storage periods vary and can be accessed through the browser.

VII. Data transfer

1. Animalhotels.com may disclose the Users' personal data at the request of public authorities or other entities entitled to such access by law, in particular when it is necessary to ensure the security of the systems or the rights of other Users, as well as at the request of Users or when it is necessary for the performance of services offered by animalhotels.com.
2. Data may be disclosed only to trusted recipients, including business partners and providers of advertising and analytics systems (e.g., Meta Platforms, Google, Microsoft), who process data on the basis of personal data entrustment agreements. All entities to whom the data is disclosed are obliged, on the basis of entrustment agreements to the extent necessary to provide services to Animalhotels.com, in particular measuring the effectiveness of marketing campaigns, creating audience groups and ad personalisation, or directly by data protection legislation, to provide appropriate technical and organisational measures to ensure an adequate level of data security. Personal data shall be processed for a period no longer than necessary for the purposes for which they were collected and processed or for the period resulting directly from the law.
3. Some Animalhotels.com service providers may store Users' data outside the European Economic Area. In such cases, Users' data may be stored in countries that provide an adequate level of personal data protection or in countries that do not provide such a level. Animalhotels.com secures Users' data by entering into agreements with animalhotels.com service providers containing the so-called Standard Contractual Clauses approved by the European Commission, which guarantee adequate security of Users' data in third countries.
4. Animalhotels.com transfers data (including phone numbers) to the SMS service provider SMSAPI to deliver verification codes and SMS notifications.
5. Animalhotels.com also transfers personal data to the following categories of recipients:
   • Stripe (Stripe Payments Europe Limited and Stripe, Inc.) to handle payments for Animal Services, payouts to Caretakers and payments for the Subscription;
   • Google (Firebase) to send push notifications;
   • Cloudflare to handle network traffic, protect against attacks and provide Cloudflare Turnstile verification;
   • OVHcloud to store files, including photos, video recordings and attachments, on servers in Poland;
   • Notion Labs to handle claims under Animalhotels Care and reports of problems with Bookings.

VIII. External links

If the services offered by animalhotels.com redirect to other websites or applications, the newly opened links do not operate in accordance with the present Privacy Policy. The User should review the privacy policies published on these websites or applications to understand their procedures for collecting, using and disclosing personal data.

IX. Use of social media plug-ins

This website uses social media plug-ins from various providers. Without the User's interference, these buttons do not send any data to the respective social networks when visiting the Website and/or the Application. Only when the given button is clicked is a direct connection established with the server of the respective social network, after which it can collect data and use cookies.

X. Data security

Animalhotels.com uses comprehensive security measures of a technical and operational nature to ensure that User data is protected against accidental or intentional manipulation, loss, destruction or access by unauthorised persons. As technology advances, the security measures used by animalhotels.com are regularly reviewed and updated.

XI. Chosen methods of personal data protection

1. The login and personal data entry areas are protected in the transmission layer (SSL certificate). This ensures that the personal and login data entered on the website are encrypted on the User's computer and may only be read on the target server.
2. User passwords are stored in hashed form. The hash function works in a one-way manner - it is not possible to reverse it.
3. Animalhotels.com periodically changes its administrative passwords.
4. Animalhotels.com makes regular backups to protect data.
5. Updating all software and programming components used by animalhotels.com to process personal data.

XII. Changes to the Privacy Policy

Animalhotels.com strives to ensure that its Privacy Policy and GDPR information are as up to date as possible. In the event of a change in legislation, case law, guidelines of the authorities responsible for supervising the processing of Personal Data, changes in technology, methods, purposes or legal basis for the processing of Personal Data, animalhotels.com will make the appropriate changes to this Privacy Policy and GDPR information, of which Users will be notified via email to the address provided by the User or by a text message to the User's phone number as well as by a message displayed on the Website and/or the Application.