Privacy Policy

This Privacy Policy (hereinafter referred to as the ‘Policy’) is that of the company that publishes the HomeExchange.com website (hereinafter referred to as ‘we’):

HomeExchange.com Inc. 625 Massachusetts Ave, Cambridge, MA 02139

DPO contact: dpo@homeexchange.com

As the data controller, Tukazza! is very committed to protecting your personal data and respecting your privacy.

The purpose of this Policy is to inform you of our practices regarding the collection, use and sharing of information that you may provide to us when you use our HomeExchange website, accessible at www.homeexchange.com/en/ (hereinafter referred to as ‘HomeExchange’).

We encourage you to carefully read this Policy, which applies when you use HomeExchange, in order to know and understand our practices regarding the processing of your personal data that We handle as well as your rights.

This Policy shall take effect as of 03/12/2019. It is subject to change at any time; in the event of substantial changes, we will inform you within a reasonable time period and, if necessary, request your consent again before it comes into effect.

Contents

1. Purpose of the Policy

To enable you to make the best use of our HomeExchange service, we may collect and use some of your information. This Policy aims to inform you of our practices and the reasons for them, in order to guarantee transparency for our users.

We undertake to use your information in compliance with the laws relating to the protection of personal data.

2. The information we collect

We collect and process the following data:

2.1. Required information that you transmit directly to us

Depending on the use of our services on HomeExchange, certain information must be provided. This is the data you transmit directly to us.

This information is required, for example, to create your account or to establish communication between your guests and yourself. These data are necessary so that we can provide you with the related service.

We, therefore, explain why we need it.

  • 2.1.1 Information concerning your identity and contact details, such as your surname, first name, email and password. This information is required when you create your HomeExchange account.
  • 2.1.2 Information concerning your accommodation, such as the nature of your accommodation (flat or house, principal or secondary residence), its location, surface area, number of bedrooms and bathrooms, number of beds, amenities and at least one photograph of your accommodation. This information is needed to add it to HomeExchange.
  • 2.1.3 Information concerning your calendar, such as dates and periods of availability of your accommodation. This information is necessary when you wish to share your home with the HomeExchange community.
  • 2.1.4 Bank details, such as your credit card number, visual ciphertext, expiry date. This information is required when you pay for a service online. These data, with the exception of the expiry date, are collected and processed directly by our payment service provider and we never store them. We keep the expiry date so that we can notify you when it expires and must, therefore, be renewed.
  • 2.1.5 Evidence required for guarantees, such as proof of cancellation or damage you have suffered. These data may be transmitted to our financial partners.

2.2. Additional and optional information that you may send us

When using our services on HomeExchange, in order to benefit from an enhanced user experience, you may be asked to provide us with additional categories of information, the provision of which is optional, such as the following:

  • 2.2.1 Additional information enriching your profile, such as your photograph, your date of birth, your telephone number, your description of yourself in your profile, languages spoken, some of your preferences, the various social networks on which you are registered.
  • 2.2.2 Additional information enriching your accommodation, such as photographs of your home, your description of your home, your neighbourhood.
  • 2.2.3 Proof of identity, such as a copy of your identity card, passport, proof of accommodation that you have added on HomeExchange. This information may enable us to verify that the information provided is accurate in order to reassure the HomeExchange community and protect our members from fraud.
  • 2.2.4 Publications, friends lists and other social interactions, such as the groups and clubs you create or join, the friends you add, the comments you write and the ratings you give.
  • 2.2.5 Private messaging. We also collect the private messages that you exchange with other members, but we treat them as confidential private correspondence in accordance with applicable regulations.

2.3. The information we automatically collect

Data may be automatically collected. We also automatically collect certain categories of information such as:

  • 2.3.1 Information arising from your use of our HomeExchange services, such as the pages you visit, the homes you add to your favourites, the searches you save, your search terms, the home exchanges you make, the GuestPoints you earn or use, your response rate and time to questions asked by other members, your last login date.
  • 2.3.2 Information concerning your equipment to access HomeExchange, such as your internet browser, screen resolution, operating system version and IP address.
  • 2.3.3 Connection logs that correspond to our servers’ log files. The information contained may be your IP address, the type of browser used, your operating system, the pages viewed, the pages from which you came.
  • 2.3.4 Cookies. We also use cookies that allow us to automatically collect certain information. For more information, see section 8 Cookies of this Policy.

3. The use of the data we collect

We use the data we collect for the following purposes:

Finalites Fondement legal
3.1 to execute contracts concluded between you and us or between our business partners and us and to provide you with the services requested
For example:
- Payment of the deposit: we need your direct debit authorisation
- Verification: We need your proof of identity and a proof of address in order to give you verified membership status
- Guarantees: in the event of an incident, we need to know if you have chosen Service Plus and any proof related to the creation of a file, which must be kept until the file is resolved (photos, medical proof, repair and/or replacement estimates, etc.)		 This processing is necessary for the performance of our respective contractual obligations, in accordance with our General Terms and Conditions of Use, accepted when creating your account and using HomeExchange.
3.2 to allow you to customise your profile in order to share more information with the HomeExchange community, socialise and reassure other HomeExchange members who would like to welcome you to their home or be welcomed at your home.
For example:
- Your description of yourself, the languages you state you speak, the photograph added to your account		 This processing is done based on your consent.
3.3 to verify your identity and to certify your member account in order to enjoy the trust of the other members of the HomeExchange community This processing is done based on your consent.
3.4 to answer your questions and assist you with your requests
For example : 
- Questions about how to use our services
- To inform us of a dispute with another member
- To lodge a complaint or request to exercise your rights		 This processing is necessary for the performance of our respective contractual obligations.
3.5 to send you newsletters and notifications regarding HomeExchange community news and to notify you when there is activity on your account
For example :
- A member wants to become your friend
- A member replied to your messages
- A member adds your home to their favourites		 This processing is done based on your consent.
However, you can opt-out and ask us to stop sending these emails, by expressing your choice in your personal space (Once logged in, click on ‘My Profile’ then ‘Settings’) or by unsubscribing using the link at the bottom of our emails.
3.6 to send you emails, SMS and marketing messages This processing is done based on our legitimate interest.
3.7 to prevent fraud and illegal activities
We have a legitimate interest in verifying certain suspicious behaviours of users on HomeExchange and carrying out verifications of information, in order to combat fraud (identity theft) abuse (creation of false accounts) and any illegal activity (hacking) or activity contrary to public order. We believe that you can reasonably expect us to perform these transactions and that they do not infringe on your rights and freedoms.
We are likely to implement automated detection systems and to humanly verify the relevance of suspicions that our systems detect.		 This processing is necessary in order to protect HomeExchange members and protect them from attempts at fraud, which is a legitimate interest
3.8 to analyse the use of our services
We analyse the behaviour of visitors to our website (interactions on the pages, use of features, search terms) in order to develop it, improve the relevance of search suggestions, modify our interfaces and our use paths when we detect that they are not intuitive enough for visitors.
In addition, we regularly send questionnaires to all or part of our members in order to better understand their use of the site and help us improve it. Participation in these surveys is optional, and each time we specify the objective of the study, as well as the processing that will be made of the collected data.		 This processing is necessary to provide you with better service and to allow our teams to make our website more attractive in order to facilitate your navigation, which is a legitimate interest.
3.9 to collect your payments or forward to you the sums collected on your behalf This processing is necessary for the performance of our respective contractual obligations.
3.10 to store connection logs 
For example :
- IP address
- type of browser used
- operating system
- pages viewed
- pages of provenance, times
- dates of visit to the site		 This processing is based on a legal obligation to keep logs of connections to HomeExchange for a period of one year.
3.11 to perform profiling operations 
Profiling consists, for example, of evaluating personal aspects, predicting behaviour or preferences.
We do several types of profiling: one to recommend houses that could potentially please our users, another to improve the order of houses appearing in our search engine, and, finally, we calculate a notion of similarity between houses.		 This processing is based on the legitimate interest to strengthen and personalise the service offering according to your interests.
3.12 to participate in studies and research
Because of our positioning and our business activity, we participate in university studies and research, for example, on the home swapping market and the sharing economy. All your data are anonymised for the purpose of these studies and used for statistical purposes only.		 This processing is anonymised.
3.13 to share your photos in our media
We may use certain house photos in the company's communication materials (newsletter, blog, advertising, etc.). These photographs are anonymous and do not reveal any private elements and are taken in respect of image rights.		 contract-based (terms of use). However you can opt out and ask us to stop using your medias if you do not want to share it

For processing performed on the basis of your consent, you may withdraw your consent at any time by removing the information from your account yourself. Our consent collection processes are currently being modified to correspond to personal data protection obligations.

4. Data retention periods

How long we keep your information depends on the nature of the data and the purposes for which we needed to collect it.

Generally speaking, we undertake to maintain the information contained in your profile for a period of three years from our last contact with you (for example, your last connection to HomeExchange). Beyond this period of three years, we will automatically delete your account and all associated data. This project is currently being set up within our company.

Nevertheless:

  • - for legal and accounting obligations, we may retain certain information for a maximum period of 10 years from their date (commercial limitation period);
  • - for evidentiary reasons: information collected for management and technical assistance purposes may be kept for a maximum period of five years from their date (civil limitation period);

More specifically, when you exercise your rights recognised by the regulations on the protection of personal data, we can keep a copy of your identity documents for a maximum period of one year for your requests for access and rectification rights and a period of three years for requests for objection rights.

5. The recipients of our data

5.1. HomeExchange members with whom you are communicating

When you exchange accommodation with another HomeExchange member, you will receive information from each other: this includes information about your identity, your contact details and the address of your accommodation.

5.2. Other companies belonging to our group

Your information may be processed by our various departments (Marketing Department, Customer Relations Department, IT Department) as well as by the various companies making up our group (Tukazza Adriatica (Croatia), Tukazza Inc. (USA), Home Exchange (USA)).

5.3. Business partners or third-party service providers

We work with third-party companies with whom we share some of your information, and who are:

  • 5.3.1 Our service providers: we use a service provider only in connection with the performance of a contract between you and us or to provide and/or improve our services (for example, in connection with payments that are made on HomeExchange, or for newsletter management);

By subscribing to our damage and cancellation offers, we are required to transfer your data to our insurance partners, for the sole purpose of the fulfilling of their contractual obligations.  These data include:

  • Identity information (name, last name...)
  • Contact details (email, phone number…)
  • Historical record of your relationship with HomeExchange (seniority, number of exchanges done…)
  • 5.3.2 Our business partners: we have business partners who can advertise our services and whose offers you can agree to subscribe to;
  • 5.3.3 Social networking platforms: we offer the possibility to use HomeExchange and to connect via social networks and can use them to offer you the best offers.

6. Storage of your information

We prefer to store your information, as much as possible, within the European Union. For example, our servers are located within the European Union.

However, we may use service providers who process the information we provide to them outside the European Union. When this happens, we first ensure that the recipient offers appropriate guarantees to process your information with a level of protection at least equivalent to the protection that European Union law offers you.

7. Transfer of your data

As a general rule, we endeavour to keep your personal data within the European Union.

Nevertheless, since some of our subsidiaries are located in countries outside the European Union, namely, the United States, we transfer some of these data to the United States. In this case, we ensure that this transfer is carried out in accordance with the regulations in force and guarantees the level of protection required by the latter.

For more information, please contact our DPO (dpo@homeexchange.com) so that we can provide you with more information about these transfers.

8. Our use of cookies

We use cookies and trackers for various reasons:

8.1 Technical cookies

We need to store these cookies so that you can use the basic functions of our website and to offer you improved, personalised functions.

For example, technical cookies will allow us to know that you are connected, to offer you the language of your choice, to display the website according to your display preferences, to better manage the load on our servers, etc.

8.2 Audience measurement cookies

We place these cookies to better understand how you browse our website, what other website you came from, what content will get your attention, which pages you visit most regularly, etc. This allows us to improve our service.

8.3 Advertising cookies

We place advertising cookies to display ads that may be of interest to you. These advertising cookies collect your browsing habits on our website and/or on other websites on which these cookies are also present in order to create a profile of your interests. These third-party cookies are produced by the advertising agencies themselves.

For these advertising cookies, you can also indicate your objection to tracking cookies Your Online Choices: http://youronlinechoices.com/fr/controler-ses-cookies/, offered by the digital advertising professionals grouped within the European association EDAA (European Digital Advertising Alliance).

8.4 Social network / third-party cookies

We place social network cookies to allow you to share content on the leading social networks. These third-party cookies are produced by the social networks themselves.

9. How can I prevent the use of cookies?

You can block the use of cookies in several ways.

By configuring your browser:

10. Your rights

You have several rights with respect to your information that we possess:

Right of access

You may ask us to access any information we hold about you.

Right to rectification

You may ask us to correct your information.

Most of the time, you can make corrections yourself when you are connected to our website.

Right to object

You may ask us to stop using your information when we do so because of a legitimate interest.

You may also ask us to stop sending you direct marketing / prospecting messages. You can easily do this when you are connected to our website by going to the ‘My Profile’ tab and then ‘Settings’ or by unsubscribing by clicking on the link provided at the bottom of our emails.

Right to withdraw consent

Where you have given us your consent to use your information for a specific purpose, you may, at any time, decide to withdraw your consent and we will then stop using your information for that purpose.

You can easily do this when you are connected to our website by going to the ‘My Profile’ tab and then ‘Settings’

Right to erasure or right to be forgotten

You may ask us, via email to our data protection officer, to delete your information or to stop using it.

We can only do this when possible: sometimes we need your information to comply with the law or simply to provide you with our services.

Right to restriction of processing

You may ask our data protection officer by email to block the use of your information, i.e. to temporarily store it but to stop using it.

Right to portability

You may contact our data protection officer to request an export of your information in a reusable format.

Right to lodge a complaint

You may lodge a complaint with the authority responsible for protecting personal data (in France, the CNIL www.cnil.fr) if you believe that your rights have not been respected.

11. Exercising your rights

To exercise your rights, contact our data protection officer (DPO) at the address given in section 12 of the Policy.

We will do our best to answer you within one month.

Any refusal of a request will be documented and explained.

Proof of identity is required for all requests to exercise rights (except in special exceptions).

12. Your DPO contact

Protecting your information is important to us. That is why we have appointed a data protection officer. He or she is the best person to answer all your questions about personal data.

You can contact us in several ways:

By email: dpo@homeexchange.com

HomeExchange.com Inc. 625 Massachusetts Ave, Cambridge, MA 02139

13. The California Consumer Privacy Act (CCPA)

The California Consumer Privacy Act (CCPA) protects the data rights of residents of the State of California, USA.

HomeExchange does not meet any of the 3 criteria laid out in the Act, so we are not legally obligated to abide by its rules. However, your privacy is important to us; we have therefore set ourselves high standards in data protection, and our Privacy Policy follows or goes beyond most of the CCPA’s requirements.

The CCPA requires that companies post a link regarding a “Do Not Sell My Personal Information” enabling users to opt out of having their data sold to third parties. In our case, we NEVER sell any member data to any third party. Your home and your information are safe with us.

If you live in California and you wish to have more visibility on how our Privacy Policy compares to the CCPA, please feel free to reach out to our Data Protection Officer :    dpo@homeexchange.com