Privacy Policy

1.1 Thank you for using Jumble! Your trust is important to us and we’re committed to protecting the privacy and security of your personal information. The information that’s shared with us helps us to provide a great experience. This Privacy Policy describes how we collect, use, process, and disclose your personal informations.

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

3.1 This Privacy Policy also applies to the Booking service. When using the Booking Services, you will be also providing your information, including personal information, to the Data Controller.

4.1 Information You Give to Us.

4.1.1. Information that is necessary for the use of the Jumble We ask for and collect the following personal information about you when you use the Jumble website. This information is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all the requested services. To use certain features of the Jumble Website (such as booking or creating a Listing), we may require you to provide certain financial information (like your bank account or credit card information) in order to facilitate the processing of Bookings.

4.1.2. Information you choose to give us. You may choose to provide us with additional personal information (such as gender, preferred language(s), city, and a personal description). This additional information will be processed based on our legitimate interest or when applicable, your consent.

4.1.3. Information that is necessary for the use of the Booking Services. The Bookings Data Controller needs to collect the following information necessary for the adequate performance of the contract with you and to comply with applicable law (such as anti-money laundering regulations). Without it, you will not be able to use Booking Services. When you use the Booking Services, the Bookings Data Controller requires certain financial information (like your bank account or credit card information) in order to process Bookings and comply with applicable law.

4.2 Information We Automatically Collect from Your Use of the Jumble

When you use the Jumble website, we automatically collect personal information about the services you use and how you use them. This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of Jumble website services.

4.2.1. Usage Information. We collect information about your interactions with the Jumble Website such as the pages or content you view, your searches for Listings, bookings you have made, and other actions on the Jumble Website.

4.2.2. Cookies and Similar Technologies. We use cookies and other similar technologies when you use our website, use our mobile app, or engage with our online ads or email communications. We may collect certain information by automated means using technologies such as cookies, web beacons, pixels, browser analysis tools, server logs, and mobile identifiers. In many cases the information we collect using cookies and other tools is only used in a non-identifiable without reference to personal information. For example, we may use information we collect to better understand website traffic patterns and to optimize our website experience. In some cases we associate the information we collect using cookies and other technology with your personal information. Our business partners may also use these tracking technologies on the Jumble Website or engage others to track your behavior on our behalf.

4.2.3. Pixels and SDKs. Third parties, including Facebook, may use cookies, web beacons, and other storage technologies to collect or receive information from our websites and elsewhere on the internet and use that information to provide measurement services and target ads. For apps, that third parties, including Facebook, may collect or receive information from your app and other apps and use that information to provide measurement services and targeted ads. Users can opt-out of the collection and use of information for ad targeting by updating their Facebook account ad settings and by contacting info@jumbleproject.com with a description of your request and validation information. Users can access a mechanism for exercising such choice by going to http://www.aboutads.info/choices and http://www.youronlinechoices.eu/.

4.2.4. Booking Transaction Information. Jumble collects information related to your Booking transactions through the Jumble Website, including the Booking instrument used, date and time, Booking amount, Booking instrument expiration date and billing postcode, PayPal email address, IBAN information, your address and other related transaction details. This information is necessary for the adequate performance of the contract between you and Jumble and to allow the provision of the Booking Services.

4.3 Information We Collect from Third Parties.

Jumble may collect information, including personal information, that others provide about you when they use Jumble Website and the Booking Services, or obtain information from other sources and combine that with information we collect through the Jumble Website and the Booking Services. We do not control, supervise or respond for how the third parties providing your information process your Personal Information, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.

4.3.1. Third Party Services. If you link, connect, or login to your Jumble Account with a third party service (e.g. Google, Facebook, WeChat), the third party service may send us information such as your registration, friends list, 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.

4.3.2. Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or information to help detect fraud and safety issues, 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 (with your consent where required) 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 Jumble Website through partnerships, or about your experiences and interactions from our partner ad networks.

4.4 Children’s Data.

Our websites and applications are not directed to children under 18 and we do not knowingly collect any personal information directly from children under 18. If you believe that we processing the personal information pertaining to a child inappropriately, we take this very seriously and urge you to contact us using the information provided under the “Contact Us” section below.

We may use, store, and process personal information to (1) provide, understand, improve, and develop the Jumble Website, (2) create and maintain a trusted and safer environment and (3) provide, personalize, measure, and improve our advertising and marketing.

5.1 Provide, Improve, and Develop the Jumble Website.

We may use the personal information to provide, improve, and develop the Jumble Website such as to:

• enable you to access and use the Jumble Website
• operate, protect, improve, and optimize the Jumble Website and experience, such as by performing analytics and conducting research
• provide customer service
• send you service or support messages, updates, security alerts, and account notifications
• if you provide us with your contacts’ information, we may process 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
• to operate, protect, improve, and optimize the Jumble Website and experience, and personalize and customize your experience (such as making Listing suggestions, ranking search results)
• enable your use of our enterprise products.

We process this personal information for these purposes given our legitimate interest in improving the Jumble Website and our Members’ experience with it, and where it is necessary for the adequate performance of the contract with you.

5.2 Create and Maintain a Trusted and Safer Environment.

We may use the personal information to create and maintain a trusted and safer environment such as to:

• detect and prevent fraud, spam, abuse, security incidents, and other harmful activity
• conduct security investigations and risk assessments
• conduct checks against databases and other information sources, including background or police checks, to the extent permitted by applicable laws and with your consent where required
• comply with our legal obligations
• resolve any disputes with any of our Members and enforce our agreements with third parties
• enforce our terms&conditions and other policies
• in connection with the activities above, we may conduct profiling based on your interactions with the Jumble Website, your profile information and other content you submit to the Jumble Website, and information obtained from third parties. In limited cases, automated processes may restrict or suspend access to the Jumble Website if such processes detect activity that we think poses a safety or other risk to the Jumble Website, our community, or third parties. If you challenge the decisioning based on the automated process, please contact us as provided in the Contact Us section below.

We process this personal information for these purposes given our legitimate interest in protecting the Jumble Website, to measure the adequate performance of our contract with you, and to comply with applicable laws.

5.3 Provide, Personalize, Measure, and Improve our Advertising and Marketing.

We may use the personal information to provide, personalize, measure, and improve our advertising and marketing such as to:

• send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences (including information about Jumble or partner campaigns and services) and social media advertising through social media websites such as Facebook or Google)
• personalize, measure, and improve our advertising
• administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Jumble or its third party partners
• conduct profiling on your characteristics and preferences (based on the information you provide to us, your interactions with the Jumble Website, information obtained from third parties, and your search and booking history) to send you promotional messages, marketing, advertising and other information that we think may be of interest to you
• no fee is charged for sending promotional emails to you, but third-party data rates may apply.

We will process your personal information for the purposes listed in this section given our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest.

5.4 How the Bookings Data Controller uses the Personal Information Collected.

We may use the personal information as a part of Booking services such as to:

• Enable you to access and use the Booking Services
• Detect and prevent fraud, abuse, security incidents, and other harmful activity
• Conduct security investigations and risk assessments
• Conduct checks against databases and other information sources
• Comply with legal obligations (such as anti-money laundering regulations)
• Enforce the Booking Terms and other Booking policies
• With your consent, send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences.

The Bookings Data Controller processes this personal information given its legitimate interest in improving the Booking Services and its users’ experience with it, and where it is necessary for the adequate performance of the contract with you and to comply with applicable laws.

6.1 Advertising and Social Media; Sharing With Your Consent.

Where you have provided consent, we share your information, including personal information, as described at the time of consent, such as when you authorize a third party application or website to access your Jumble Account or when you participate in promotional activities conducted by Jumble partners or third parties. Where permissible according to applicable law we may use certain limited personal information about you, such as your email address, to hash it and to share it with social media websites, such as Facebook or Google, to generate leads, drive traffic to our websites or otherwise promote our products and services or the Jumble Website. These processing activities are based on our legitimate interest in undertaking marketing activities to offer you products or services that may be if your interest. The social media websites with which we may share your personal information are not controlled or supervised by Jumble. Therefore, any questions regarding how your social media website service provider processes your personal information should be directed to such provider. Please note that you may, at any time ask Jumble to cease processing your data for these direct marketing purposes by sending an e-mail to info@jumbleproject.com.

6.2 Profiles, Listings, and other Public Information.

The Jumble Website lets you publish information, including personal 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
• Listing pages are publicly visible and include information such as the Accommodation or Experience’s approximate location (neighborhood and city) or precise location (where you have provided your consent), Listing description, calendar availability, your public profile photo, aggregated demand information (like page views over a period of time), and any additional information you choose to share
• After completing a booking, Guests and Hosts may write Reviews and rate each other. Reviews and Ratings are a part of your public profile page and may also be surfaced elsewhere on the Jumble Website (such as the Listing page)
• If you submit content in a community or discussion forum, blog or social media post, or use a similar feature on the Jumble Website, that content is publicly visible.

Based on our legitimate interest to promote the Jumble Website we may display parts of the Jumble Website (e.g., your Listing page) on sites operated by Jumble’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.

Information you share publicly on the Jumble Website 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.

6.3 Compliance with Law, Responding to Legal Requests, Preventing Harm and Protection of our Rights.

Jumble may disclose your information, including personal information, to courts, law enforcement, governmental authorities, tax authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with a valid legal request or to respond to claims asserted against Jumble, (iii) to respond to a valid legal request relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability (iv). For example, if permitted due to the forgoing circumstances, Host tax information may be shared with tax authorities or other governmental agencies.

These disclosures may be necessary to comply with our legal obligations, for the protection of your or another person’s vital interests or for the purposes of our or a third party’s legitimate interest in keeping the Jumble Website secure, preventing harm or crime, enforcing or defending legal rights, facilitating the collection of taxes and prevention of tax fraud or preventing damage.

Where appropriate, we may notify Members about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon Jumble’s property, its Members and the Jumble Website. In instances where we comply with legal requests without notice for these reasons, we may attempt to notify that Member about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.