Privacy Policy for RoomMatch

Last Updated: September 30, 2019

RoomMatch, Inc. (“RoomMatch”, "us", "our" or "we") has developed this Privacy Policy to explain who we are, how we collect, use and share personal information about you, and how you can exercise your privacy rights.

This Privacy Policy describes how we collect and use personal information in the usual course of business, including through our website www.roommatch.com and any of its sub-domains which include a link to this Privacy Policy (the "Sites"), and our member database or other public forums (“Community Forums”) as well as in connection with any of our sales or marketing activities (collectively, “Services”). This Privacy Policy applies to your use of the Sites (however accessed and/or used, whether via personal computers, mobile devices or otherwise) or any other means or applications in which you connect with us and your use of our Services.

This Privacy Policy is subject to our Terms of Use. Each time that you access, register and/or use the Sites or our Services you signify that you have read, understand, and agree to be bound by the Terms of Use, and this Privacy Policy. If you do not agree to the Terms of Use and this Privacy Policy, you must discontinue using the Sites or Services.

QUICK LINKS

We recommend that you read this Privacy Policy in full to ensure you are fully informed. However, to make it easier for you to review those parts of this Privacy Policy which apply to you, we have divided up the document into the following sections:

1. Who We Are
2. What Information We Collect
3. How We Use Your Information
4. How We Share Your Information
5. Your Data Protection Rights
6. EEA and UK Data Subjects’ Privacy Rights
7. Nevada Residents’ Privacy Rights
8. Third-Party Links
9. International Users
10. How We Keep Your Personal Information Secure
11. Retention of Your Personal Information
12. Children’s Information
13. Changes to Privacy Policy
14. Disputes
15. No Rights of Third Parties
16. Contact Us

1. WHO WE ARE
We are a US-based company which has created an online marketplace that enables users, who are either a host using our Services to list a room for rent or a potential roommate looking for a room or apartment to rent, to communicate through our proprietary platform and thereafter transact directly with each other.

2. WHAT INFORMATION WE COLLECT
• Information you provide to us: You may provide personal information to us when you sign up for an account to access and use the Services, when you consult with customer support or send us an email or communicate with us in any way (for example, to make a support request) or post a profile. The personal information we collect may include: your contact information (such as your name, address, telephone number and email address) and contact preferences; account information (such as your username and password); and profile demographics you choose to provide to us. If you ever communicate directly with us, we may maintain a record of those communications and responses.
• Information You Post. Our Platform is designed to enable you to post your profile to help you find roommates or housing and any information or content you put in your profile or post directly in a community forum becomes public information and is potentially subject to redistribution by RoomMatch and other third parties who have access to the member database or community forum. There is no expectation of privacy when posting content in a profile or communicating in a community forum and we have no control over how users may use the information you make public. Therefore, you should exercise caution and discretion when deciding to disclose your personal information in a submission or posting on a community forum.
• Location Information. We collect information about your location through your account and profile and may also collect information about your location through different technologies, including GPS and Wi-Fi which may include your precise location. We also collect IP addresses and device identifiers that may provide location information.
• Information We Collect Automatically Through Cookies and Similar Technologies. We use tracking tools like browser cookies and web beacons to automatically collect information about how you interact with our Sites and Services and other websites over time and across devices. We may also have third parties collect information this way. For more information on cookies and similar tracking technology and how they are used and how you can opt out of such use please refer to our Cookie Notice.
• Information Imported from Social Networks. When you choose to interact with us through social media your interactions with the social media platforms (“Social Networks”) typically allows the Social Networks to collect information such as “Likes”, profile information gathered from the Social Networks, or the fact that you viewed or interacted with our Services. Social Networks may collect information about you through digital cookies they place on your device and other tracking mechanisms even when you are not directly interacting with their applications. Please review the Social Networks’ privacy policies and choices for sharing information of any Social Network connected to our Services.
• Information We Collect From Other Sources. In order to enhance our ability to provide relevant marketing, offers and services to you, we may obtain information about you from other sources, such as public databases, joint marketing partners, analytics companies, data service providers, fraud detection companies. In the event we receive such data and combine it with our customer records the information we receive will be treated in accordance with this privacy policy.

3. HOW WE USE YOUR INFORMATION
We use the information we collect or receive (alone or in combination):
• to respond to your inquiries and fulfill your requests, such as to provide you access to the Services you have ordered, to respond to any inquiry, job application, feedback, or information and materials regarding our products and services.
• to share your information on our member database so that you can use our Services to find a room match.
• to send administrative information to you, for example, information regarding our Services or Sites, and changes to our Terms of Use and other policies.
• to send you marketing communications, including via email and SMS in compliance with applicable laws and in accordance with your preferences, that we believe may be of interest to you.
• to personalize your experience on our Sites by presenting content and offers tailored to you and your interests.
• To perform statistical, and marketing analyses of user behavior.
• for our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Sites and Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
• as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities; (d) to enforce our Terms of Use; (e) to protect our operations or any of our marketing partners; (f) to protect our rights, privacy, safety or property, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
• for other reasons that we may describe to you at the time of collection.

4. HOW WE SHARE YOUR INFORMATION
We may disclose your personal information to the following categories of recipients:
• Service Providers. In order to provide our Services to you, it is necessary for us to disclose your information to contracted third parties and service provider partners who perform certain functions of our Services on our behalf. Examples include cloud hosting providers (to provide data storage and processing services) or communications providers (to process new queries and to manage our emails).
• Targeted Advertising. We may share your information collected about your visits over time and across our Services, multiple devices and other websites in order to serve targeted advertising to you. For more information on targeted advertising and how to manage your preferences please refer to our Cookie Notice.
• Compliance with Laws. We may disclose information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or other legal process (including in response to public authorities to meet national security or law enforcement requirements).
• Marketing Partners. We selectively share your information with third parties so that they might provide you with information about their products or services offering which may be of interest to you. See Section 5 for how to opt out of our sharing of your information for these purposes.
• Vital Interests and Legal Rights. We may disclose information where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Use or this Privacy Policy, or as evidence in litigation in which RoomMatch may be involved.
• Business Transfers. We may share or transfer information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Policy.
• Consent. We may share your information with any other person with your consent to the disclosure.

5. YOUR DATA PROTECTION RIGHTS
• Access to Information. You can access, correct, update, delete, and add personal information you have provided to us by going to your account or profile. If you need assistance you can email us at privacy@roommatch.com or write to us at RoomMatch, P.M.B. 600, 11271 Ventura Blvd, Studio City, CA 91604.
• Opting-Out of Marketing Emails. You can opt out of receiving marketing emails from us or third parties by clicking the “unsubscribe” link in the email. You can also email us at privacy@roommatch.com or write to us at RoomMatch, P.M.B. 600, 11271 Ventura Blvd, Studio City, CA 91604. If you choose to no longer receive marketing information, we may still communicate with you regarding such things as security updates, product functionality, responses to service requests, or other transactional, non-marketing purposes. Please note that changes may not be effective immediately, but we will endeavor to comply with your request as soon as reasonably possible.
• Turning Off Tracking Technologies. You can choose to have your computer warn you each time a persistent or session cookie is being sent, or you can choose to turn off such cookies through your browser settings. Each browser is a little different, so look at your browser’s Help menu to learn the correct way to modify your cookies. It is important to remember that many of our Services may not function properly if your cookies are disabled. Please refer to our Cookie Notice for more information.
• Browser “Do Not Track” Signals. Some third-party browsers provide “do not track” machine readable signals for websites, which are automatically applied by default. These features are not all uniform. We do not currently respond to those signals. If you block cookies, certain features on our Sites may not work. If you block or reject cookies, not all of the tracking described here will stop.
• Interest Based Ads. Please refer to our Cookies Notice for opt out information.
• Control Tools on Your Mobile Devices. There may be controls on your mobile devices such as the ability to turn off GPS locator and other privacy settings.
• Consent. If we have collected and processed your personal information with your consent, then depending on the jurisdiction where you reside and applicable law you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
• Timing and Third Parties. We will endeavor to comply with your request for changes as soon as reasonably possible. Unless required by law, we are not responsible for informing third parties with whom we have already shared your information of any changes requested pursuant to this section, or for removing information from or causing information to be removed from the databases or records of such entities.

6. EEA AND UK DATA SUBJECTS’ PRIVACY RIGHTS
Legal Basis. If you are a visitor from the EEA or the UK, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so.
If we collect and use your personal information in reliance on our legitimate interests (or those of a third party), this interest will normally be to operate our services and communicate with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving the services we offer, or for the purposes of detecting or preventing illegal activities.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided.
EEA and UK Data protection Rights. If you are located in the EEA or UK, you have the following data protection rights:
• Right of Access. If you wish to access your personal information, you can do so at any time by logging into your account or by contacting us at GDPRDataRequest@roommatch.com or using the contact details provided in Section 16 below.
• Right to Correction. If you wish to correct or update your personal information, you can do so at any time by logging into your account or by contacting us at GDPRDataRequest@roommatch.com or using the contact details provided in Section 16 below.
• Right to Erasure. If you wish to request deletion of your personal information, you can do so at any time by contacting us at GDPRDataRequest@roommatch.com or using the contact details provided in Section 16 below.
• Right to Restriction of Processing. In addition, in certain circumstances you can object to processing of your personal information or ask us to restrict processing of your personal information by contacting us at GDPRDataRequest@roommatch.com or using the contact details provided in Section 16 below.
• Right to Data Portablity. In certain circumstances you can request portability of your personal information by contacting us at GDPRDataRequest@roommatch.com or using the contact details provided in Section 16 below.
• Right to Withdraw Consent. If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
• Lodging a Complaint. You have the right to complain to a data protection authority about our collection and use of your personal information. For more information please contact your local data protection authority.

7. NEVADA RESIDENTS’ PRIVACY RIGHTS
A Notice to Nevada Residents: Under Nevada law, Nevada residents may opt out of the sale to third parties of certain personal information we have collected or will collect about them. Any Nevada resident may choose to opt-out of the sale of such personal information at any time by directing such request to NevadaPrivacyRequest@roommatch.com.

8. THIRD-PARTY LINKS
This Privacy Policy only applies to the Sites and Services. Any access to and use of any linked websites or services is not governed by this Privacy Policy but instead is governed by the privacy policies of those third parties. We are not responsible for the information practices of such third parties.

9. INTERNATIONAL USERS
The Sites and Services are provided and hosted in the United States. If you are using the Sites or Services from outside the United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information, in the United States and other locations. These countries may have data protection laws that are different to the laws of your country. By using the Services, you consent to the collection, international transfer, storage, and processing of your personal information.

10. HOW WE KEEP YOUR PERSONAL INFORMATION SECURE
We have implemented appropriate physical, technical and administrative safeguards against unauthorized access, use, modification and disclosure of personal information in our custody and control. However, no data transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so you should take care in deciding what information you send us in this way.

11. RETENTION OF YOUR PERSONAL INFORMATION
We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to comply with applicable legal, tax or accounting requirements, to maintain records of fraud, to enforce our agreements or comply with our legal obligations), or in accordance with our standard business practices.

12. CHILDREN'S INFORMATION
The Sites and Services are intended for a general audience and is not directed or intended for anyone under 18 years of age. You must be 18 years or the age of majority in the jurisdiction where you reside to use the Sites or Services. Any information we receive from people we believe to be under this age will be purged from our database. We do not knowingly collect personal information from children under the age of 18 or have any reasonable grounds to believe that children under the age of 18 are accessing our Sites or using or accessing our Services. By registering you attest that you that you are the age of majority and have the capacity to be legally bound by these Terms.

13. CHANGES TO PRIVACY POLICY
RoomMatch will review and update this Privacy Policy periodically and will note the date of its most recent update above. If we make material changes to this Privacy Policy, we may notify you by prominently posting a notice of a new Privacy Policy update, but we encourage you to review this Privacy Policy frequently to be informed of how Roommatch is using your information.

14. DISPUTES
If you choose to visit the Sites use our Services any dispute over privacy is subject to this Privacy Policy and our Terms of Use including limitations of liability, the resolution of disputes and application of the laws of the United States, the Federal Arbitration Act and the laws of the State of Florida.

15. NO RIGHTS OF THIRD PARTIES
This Privacy Policy does not create rights enforceable by third parties or require disclosure of any Personal Information relating to visitors to or users of the Sites or Services.

16. CONTACT US
If you have any questions, comments or concerns about this Privacy Policy or our privacy practices email us at privacy@roommatch or write to us at Roommatch, Inc., P.M.B. 600, 11271 Ventura Blvd, Studio City, CA 91604.
When contacting us, please include your full name, address, phone number, and email address, and indicate the specific nature of your request or inquiry.
The data controller of your personal information is RoomMatch, Inc.