Savvy Privacy Policy

Introduction

finderco, LLC and its affiliates (collectively, “finderco,” “Savvy,” “we,” “us,” or “our”) respect your privacy and are committed to protecting it through our compliance with this policy. Savvy was formerly known as bnbfinder.

This policy describes the types of information we collect from or about you, and how we collect, use, maintain, protect, disclose, and otherwise process it, when you use services accessible via www.savvy.com or any other website, IP address, social media account, iOS app, Android app, web app, or other online product or service offered by finderco (collectively, the “Service”), and in email, text, and other electronic messages between you and the Service.

The Service is a marketplace that connects Hosts who offer short-term lodging with Guests who book it. Depending on how you use the Service, you may be a Guest, a Host, a website visitor, or more than one of these. This policy explains the practices that apply to each.

This policy does not apply to information collected by any third party, including through any application or content (including advertising) that may link to or be accessible from the Service, or to any Host’s own collection or use of your information. Hosts are independent businesses and are solely responsible for their own privacy practices, and we are not liable for their handling of your information.

Please read this policy carefully. If you do not agree with our policies and practices, do not use the Service. We may change this policy from time to time as described in “Changes to This Policy” below, and we will indicate when it was last revised. For material changes, we will endeavor to provide notice as described in that section.

1. Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include publicly available information, deidentified or aggregated information, or information otherwise excluded from the scope of applicable privacy laws.

A. Information You Provide to Us

• Account and profile information, such as your name, email address, telephone number, mailing address, username and password, and, for Hosts, business name and listing details.
• Payment and financial information. When you make or receive payments through the Service, our payment processor collects and processes your payment card or bank account information, billing address, and related details. For Hosts who receive payouts, we or our payment processor collect payout account information and tax identification information, including your Form W-9 or W-8 and taxpayer identification number, which we use to make payouts and meet tax-reporting obligations. We do not store full payment card numbers on our own systems. Card data is handled by our PCI-DSS-compliant payment processor.
• Transaction information, such as bookings, reservations, cancellations, subscription plans, commissions, dates of stay, and communications relating to a Reservation.
• Communications and content, such as messages, reviews, photos, listing content, survey and contest responses, and records of your correspondence with us or other users.
• Identity and verification information where required by law or to prevent fraud, such as government-issued identification, and, for Hosts, short-term-rental registration or permit numbers we are required to collect or verify under applicable local law.

We generally do not request a Social Security number from Guests. Where we collect a taxpayer identification number from a Host for payout and tax-reporting purposes, we treat it as sensitive information and protect it accordingly.

B. Information We Collect Automatically

As you navigate through and interact with the Service, we may use cookies, web beacons, and similar technologies to automatically collect:

• Usage details, such as traffic data, logs, the resources you access, and dates and times of access;
• Device and connection information, such as IP address, device identifiers, operating system, browser type, carrier, and mobile device model; and
• Location information. With your permission, our mobile app may collect precise geolocation from technologies such as GPS, Wi-Fi, or cell-tower proximity; you can disable this in your device settings. We also infer approximate location from your IP address.

See “Cookies and Tracking Technologies” below for how to control these technologies, including through the Global Privacy Control.

C. Information From Third Parties

• Payment processors and financial partners, which confirm payment status and help prevent fraud;
• Affiliates and channel or distribution partners through which Listings or bookings may originate;
• Identity, fraud-prevention, and screening providers, including sanctions and watchlist screening; and
• Analytics and advertising providers, and social media platforms when you interact with our content.

D. Categories We Have Collected

In the last twelve (12) months, we have collected the following categories of personal information (using the category labels from the California Consumer Privacy Act, as amended):

We do not use or disclose “sensitive personal information” (as defined by applicable law, which may include precise geolocation and government identifiers) for purposes that would require us to offer a right to limit its use, other than to provide the Service, comply with law, prevent fraud, and other purposes for which a right to limit does not apply.

2. How We Use Your Information

We use personal information for the following business and commercial purposes:

• To provide the Service, including to create and manage your account, publish Listings, and facilitate searches, bookings, and Reservations;
• To process payments and payouts, including to charge Guests, collect our fees and commissions, remit payouts to Hosts, process refunds, and handle chargebacks and payment disputes;
• To manage subscriptions, including billing, renewals, and cancellations;
• To calculate, collect, and remit taxes, and to meet tax-reporting and information-return obligations (for example, Form 1099-K), where required by law;
• To verify Listings and comply with short-term-rental laws, including verifying registration where a jurisdiction requires it before a booking may proceed or a fee may be charged, and to make any reports to regulators that the law requires;
• To communicate with you, including transactional messages, customer support, and, subject to your choices, marketing;
• To personalize and improve the Service, conduct research and analytics, and develop new features;
• To protect the Service and prevent fraud and abuse, including security monitoring, identity verification, and sanctions and watchlist screening; and
• To comply with law and legal process, enforce our Terms of Use, and establish, exercise, or defend legal claims.

Where required by applicable law, we will not collect additional categories of personal information, or use the personal information we collected for materially different, unrelated, or incompatible purposes, without providing you notice. We may use deidentified or aggregated information for any purpose without restriction.

3. How We Disclose Your Information

We may disclose personal information as follows:

• Between Guests and Hosts, as needed to facilitate a booking or Reservation. When you book, we share the information the Host needs to provide the stay; when you host, we share the information the Guest needs to complete and use the booking.
• Service providers and processors that perform services for us, such as payment processing, hosting, analytics, customer support, communications, fraud prevention, identity verification, and tax calculation, under contracts that limit their use of the information to performing those services.
• Payment processors and financial institutions, to process payments, payouts, and refunds and to prevent fraud.
• Affiliates and channel or distribution partners through which Listings or bookings originate, to operate the Service.
• Government authorities and regulators, where required by law, including short-term-rental registration and reporting requirements (for example, transaction reporting to the New York City Office of Special Enforcement) and tax authorities.
• In corporate transactions, to a buyer or successor in a merger, financing, reorganization, dissolution, or sale of assets, in which case personal information may be among the assets transferred. If a successor entity's use of your personal information will materially differ from this policy, we or the successor will provide notice and, where required by law, obtain your consent.
• To protect rights and safety, to enforce our Terms of Use, and to comply with legal process; and with your consent or at your direction.

“Sales” and “Sharing” of Personal Information

Some state privacy laws define a “sale” broadly to include disclosures for monetary or other valuable consideration, and define “sharing” or “targeted advertising” to include disclosures of personal information for cross-context behavioral advertising. We do not sell your personal information for money. However, our use of certain advertising and analytics cookies and similar technologies may be considered a “sale” or “sharing” (or processing for targeted advertising) under some state laws. You have the right to opt out of this activity, and we honor opt-out preference signals, including the Global Privacy Control, as described in “Your Privacy Choices and Rights” and “Cookies and Tracking Technologies” below. We do not knowingly sell or share the personal information of consumers under 16 years of age without the required consent.

4. Cookies and Tracking Technologies

We use cookies (including browser and Flash cookies), web beacons, pixels, and similar technologies to operate the Service, remember your preferences, secure your session, understand usage, and, where applicable, deliver and measure advertising.

• Strictly necessary technologies enable core functions such as security, load balancing, and holding session information as you navigate the Service.
• Analytics technologies help us understand and improve how the Service is used.
• Advertising technologies, if used, help deliver and measure marketing and may involve disclosures treated as a “sale” or “sharing” under some state laws.

You can control cookies through your browser settings and, where offered, through our cookie preference tool. If you remove or reject cookies, some features of the Service may not function properly.

Global Privacy Control and opt-out preference signals. We recognize the Global Privacy Control (GPC) and other opt-out preference signals that applicable law requires us to honor. When you visit the Service from a browser or device transmitting such a signal, we will treat it as a request to opt out of the “sale” or “sharing” of personal information (and processing for targeted advertising) for that browser or device, and, where the signal is linked to an account, for that account.

5. Your Privacy Choices and Rights

A. Choices Available to Everyone

• Marketing communications. You can opt out of marketing emails using the unsubscribe link or by contacting us. We will still send transactional messages about your account, bookings, and payments.
• Location. You can disable precise location collection in your device settings.
• Cookies and opt-out signals. You can manage cookies and use the Global Privacy Control as described above.

B. State Privacy Rights

Depending on your state of residence, you may have some or all of the following rights, subject to exceptions and verification:

• Access / know the categories and specific pieces of personal information we have collected, the sources, the purposes, and the categories of recipients;
• Delete personal information we collected from you;
• Correct inaccurate personal information;
• Portability, to receive a copy of your personal information in a portable format;
• Opt out of the sale or sharing of personal information and of targeted advertising;
• Limit the use of sensitive personal information, where applicable; and
• Non-discrimination for exercising your rights, and, where applicable, the right to appeal a denial and to opt out of certain profiling.

These rights arise under the comprehensive privacy laws now in effect in various U.S. states, including but not limited to California, Colorado, Connecticut, Texas, and Virginia, among others. The specific rights and exceptions vary by state. Sensitive personal information is processed only as permitted by applicable law, and, in states that require it, with your consent.

C. How to Exercise Your Rights

You, or an authorized agent acting on your behalf, may submit a request through the contact information included below. You may also make a request on behalf of your minor child. We will verify your request using information such as your name, email, and details reasonably necessary to confirm your identity, and we may require additional verification for sensitive information or deletion requests. Making a request does not require you to create an account, and we will use information you provide only to process the request.

We generally respond within 45 days and may extend by an additional 45 days where permitted, with notice. We respond to opt-out requests within the time each applicable state requires (for example, 15 business days in California). We do not charge a fee unless your request is excessive, repetitive, or manifestly unfounded, in which case we will explain and may provide a cost estimate. If we deny a request, we will explain why, and, where the law provides, you may appeal by contacting us through the contact information provided below.

D. Nevada and “Shine the Light”

Nevada residents may direct us not to sell certain covered information. We do not sell such information as defined by Nevada law, but you may submit a request through the contact information provided below. California’s “Shine the Light” law (Cal. Civ. Code § 1798.83) permits California residents to request information about disclosures of personal information to third parties for their direct marketing purposes. You may submit such a request through the contact information provided below.

6. Financial Information (GLBA)

Some information we collect in connection with payments and payouts may be subject to the Gramm-Leach-Bliley Act (GLBA) and similar financial-privacy laws. To the extent GLBA applies to our handling of such information, we comply with its requirements, and this policy’s general provisions are supplemented by our financial-privacy practices. We limit the use and disclosure of financial account information to processing transactions, making payouts, preventing fraud, and complying with law, and we require our payment processors to maintain appropriate safeguards.

7. Retention of Your Information

We keep personal information only for as long as necessary for the purposes described in this policy, unless a longer period is required or permitted by law (for example, tax, accounting, anti-fraud, dispute-resolution, or regulatory-reporting requirements). Retention periods vary by the type of information and the purpose. For example, we retain transaction and tax records for the periods required by tax and financial-recordkeeping law, and account information for as long as your account is active and thereafter as needed. When we no longer have a legitimate need to process personal information, we delete or deidentify it, or, where that is not feasible (for example, in backups), securely isolate it until deletion is possible.

8. Security of Your Information

We implement technical, administrative, and physical safeguards designed to protect personal information, and we require our payment processors to maintain PCI-DSS-compliant safeguards for payment data. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. You are responsible for keeping your account credentials confidential. If we learn of a security breach affecting your personal information, we will notify you and any regulators as and when required by applicable law.

9. Children’s Privacy

The Service is intended for adults and is not directed to children. Users must be at least 18 to create an account or transact. Consistent with the Children’s Online Privacy Protection Act (COPPA), we do not knowingly collect personal information from children under 13. If we learn that we have collected personal information from a child under the applicable minimum age without appropriate consent, we will delete it. A parent or guardian who believes a child has provided us personal information may contact us at the address below. Some states provide additional protections for the personal information of minors under 16 or 18, including with respect to targeted advertising and sales. We honor those protections where they apply.

10. International Users and Data Transfers

The Service is operated from and intended for users in the United States. If you access the Service from outside the United States, your personal information will be transferred to, stored, and processed in the United States, where privacy laws may differ from those in your location. Where required by applicable law governing the transfer of personal information of individuals in the European Economic Area, the United Kingdom, or Switzerland, we rely on appropriate safeguards recognized under that law. Individuals in those regions may contact us with questions about such safeguards and, where applicable law provides, may have the right to lodge a complaint with their local data protection authority.

11. Third-Party Links and Services

The Service may contain links to third-party websites, applications, or services, and may make available Listings offered through affiliates or channel partners. We are not responsible for the privacy practices of those third parties, and this policy does not apply to them. We encourage you to read their privacy policies.

12. Changes to This Policy

We may update this policy from time to time. We will post the updated policy with a new “Last updated” date, and it will be effective when posted unless a later date is stated. If we make material changes, we will provide notice by prominently posting a notice on the Service or by sending you a direct notification. Where required by applicable law, we will obtain your consent before applying material changes to personal information previously collected. Your continued use of the Service after any update constitutes your acceptance of the revised policy. We encourage you to review this policy periodically.

13. Contact Us

If you have questions about this policy or our privacy practices, or wish to exercise your rights, contact our Privacy Team:

finderco, LLC, Attn: Privacy Team, 3801 N. Capital of Texas Highway, Suite E-240-308, Austin, TX 78746

Email: support@savvy.com Phone: (512) 351-3797