Last Updated: May 22, 2018
Thank you for using Brazil Nature Tours!
1. INFORMATION WE COLLECT
There are three general categories of information we collect.
1.1 Information You Give to Us.
1.1.1 Information that is necessary for the use of the Brazil Nature Tours website.
We ask for and collect the following personal information about you when you use the Brazil Nature Tours 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.
• Personal Information. When you contact us for a booking, we require certain information such as your first name, last name and email address.
• Identity Verification Information. To help create and maintain a trusted environment, we may collect identity verification information (such as images of your government issued ID, passport, national ID card, or driving license, as permitted by applicable laws) or other authentication information.
1.1.2 Information you choose to give us.
You may choose to provide us with additional personal information in order to obtain a better user experience when using Brazil Nature Tours website. This additional information will be processed based on your consent.
• Additional Profile Information. You may choose to provide additional information as part of your Brazil Nature Tours profile (such as gender, preferred language(s), city, and a personal description). Some of this information as indicated in your Account settings is part of your public profile page, and will be publicly visible to others.
• Other Information. You may otherwise choose to provide us information when you fill in a form, conduct a search, update or add information to your Brazil Nature Tours Account, respond to surveys, post to community forums, participate in promotions, or use other features of the Brazil Nature Tours website.
1.1.3 Information that is necessary for the use of the Payment Services.
The Payments Data Controller needs to collect the following information, as it is 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 Payment Services:
• Payment Information. When you use the Payment Services, the Payments Data Controller requires certain financial information (like your bank account or credit card information) in order to process payments and comply with applicable law.
1.2 Information We Automatically Collect from Your Use of the Brazil Nature Tours website.
When you use the Brazil Nature Tours website, we automatically collect information, including 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 the Brazil Nature Tours website.
• Geo-location Information. When you use certain features of the Brazil Nature Tours website, we may collect information about your precise or approximate location as determined through data such as your IP address or mobile device’s GPS to offer you an improved user experience. Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings menu. Brazil Nature Tours may also collect this information even when you are not using the app if this connection is enabled through your settings or device permissions.
• Usage Information. We collect information about your interactions with the Brazil Nature Tours website such as the pages or content you view, your searches for Listings, bookings you have made, and other actions on the Brazil Nature Tours website.
• Log Data and Device Information. We automatically collect log data and device information when you access and use the Brazil Nature Tours website, even if you have not created an Brazil Nature Tours Account or logged in. That information includes, among other things: details about how you’ve used the Brazil Nature Tours website (including if you clicked on links to third party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the Brazil Nature Tours website.
1.3 Information We Collect from Third Parties. Brazil Nature Tours may collect information, including personal information, that others provide about you when they use the Brazil Nature Tours website, or obtain information from other sources and combine that with information we collect through the Brazil Nature Tours. We do not control, supervise or respond for how the third parties providing your information process your personal data, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.
• Third Party Services. If you link, connect, or login to your Brazil Nature Tours Account with a third party service (e.g. Google, Facebook), the third party service may send us information such as your registration 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.
2. HOW WE USE INFORMATION WE COLLECT
We use, store, and process information, including personal information, about you to provide, understand, improve, and develop the Brazil Nature Tours website, create and maintain a trusted and safer environment and comply with our legal obligations.
2.1 Provide, Improve, and Develop the Brazil Nature Tours website.
• Enable you to access and use the Brazil Nature Tours website. • Operate, protect, improve, and optimize the Brazil Nature Tours website and experience, such as by performing analytics and conducting research.
• Provide customer service.
• 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 Brazil Nature Tours website and experience, and personalize and customize your experience (such as making Listing suggestions or ranking search results), we conduct profiling based on your interactions with the Brazil Nature Tours website, your search and booking history, your profile information and preferences, and other content you submit to the Brazil Nature Tours website.
We process this information given our legitimate interest in improving the Brazil Nature Tours website and our Members’ experience with it, and where it is necessary for the adequate performance of the contract with you.
2.2 Create and Maintain a Trusted and Safer Environment.
• Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity.
• Conduct security investigations and risk assessments.
• Verify or authenticate information or identifications provided by you (such as to verify your Accommodation address or compare your identification photo to another photo you provide).
• 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 of Service and other policies.
• In connection with the activities above, we may conduct profiling based on your interactions with the Brazil Nature Tours website, your profile information and other content you submit to the Brazil Nature Tours website, and information obtained from third parties. In limited cases, automated processes may restrict or suspend access to the Brazil Nature Tours website if such processes detect a Member or activity that we think poses a safety or other risk to the Brazil Nature Tours website, other Members, or third parties.
We process this information given our legitimate interest in protecting the Brazil Nature Tours website, to measure the adequate performance of our contract with you, and to comply with applicable laws.
2.3 Provide, Personalize, Measure, and Improve our Advertising and Marketing.
• Send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences (including information about Brazil Nature Tours or partner campaigns and services) and social media advertising through social media platforms 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 Brazil Nature Tours or its third party partners.
• Conduct profiling on your characteristics and preferences (based on the information you provide to us, your interactions with the Brazil Nature Tours 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.
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. You can opt-out of receiving marketing communications from us by following the unsubscribe instructions included in our marketing communications or changing your notification settings within your Brazil Nature Tours Account.
2.4 How the Payments Data Controller uses the Information Collected.
• Enable you to access and use the Payment 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 Payment Terms and other payment 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 Payments Data Controller processes this information given its legitimate interest in improving the Payment 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.
3. SHARING & DISCLOSURE
3.1 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 Brazil Nature Tours Account or when you participate in promotional activities conducted by Brazil Nature Tours partners or third parties.
3.2 Sharing between Members.
To help facilitate bookings or other interactions between Members, we may need to share certain information, including personal information, with other Members, as it is necessary for the adequate performance of the contract between you and us, as follows:
• When you as a Guest submit a booking request, certain information about you is shared with the hotels, including your full name, the full name of any additional Guests, and other information you agree to share. When your booking is confirmed, we will disclose additional information to assist with coordinating the trip, like your phone number.
• When you as a Host (or Co-Host, if applicable) have a confirmed booking, certain information is shared with the Guest to coordinate the booking, such as your full name, phone number, and Accommodation or Experience address.
• When you as a Host invite another Member to become a Co-Host, you authorize the Co-Host to access your information and Member Content, including but not limited to certain information like your full name, phone number, Accommodation address, and email address.
• When you as a Guest invite additional Guests to a booking, your full name, travel dates, Host name, Listing details, the Accommodation address, and other related information will be shared with each additional Guest. • When you as a Guest initiate a Group Payment Booking Request certain information about each participant such as first name, last initial, profile picture as well as the booking details is shared among all participants of the Group Payment Booking Request.
We don’t share your billing and payout information with other Members.
3.3 Profiles, Listings, and other Public Information.
The Brazil Nature Tours website lets you publish information, including personal information, that is visible to the general public. For example:
• 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 Brazil Nature Tours 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 Brazil Nature Tours website, that content is publicly visible.
Based on our legitimate interest to promote the Brazil Nature Tours website we may display parts of the Brazil Nature Tours website (e.g., your Listing page) on sites operated by Brazil Nature Tours’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 Brazil Nature Tours 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.
3.4 Additional Services by Hosts.
Hosts may need to use third party services available through the Brazil Nature Tours website to assist with managing their Accommodation or providing additional services requested by you, such as cleaning services or lock providers. Hosts may use features on the Brazil Nature Tours website to share information about the Guest (like check-in and check-out dates, Guest name, Guest phone number) with such third party service providers for the purposes of coordinating the stay, managing the Accommodation, or providing other services.
3.5 Compliance with Law, Responding to Legal Requests, Preventing Harm and Protection of our Rights.
Brazil Nature Tours and Brazil Nature Tours Payments may disclose your information, including personal information, to courts, law enforcement or governmental 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) comply with our legal obligations, (ii) to comply with legal process and to respond to claims asserted against Brazil Nature Tours, (iii) to respond to verified requests 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) to enforce and administer our Terms of Service, the Payment Terms or other agreements with Members, or (v) to protect the rights, property or personal safety of Brazil Nature Tours, its employees, its Members, or members of the public.
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 Brazil Nature Tours’s property, its Members and the Brazil Nature Tours website. In instances where we comply with legal requests without notice for these reasons, we will 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.
3.6 Service Providers.
Brazil Nature Tours and Brazil Nature Tours Payments uses a variety of third party service providers to help us provide services related to the Brazil Nature Tours website and the Payment Services. Service providers may be located inside or outside of the European Economic Area (“EEA”). In particular, our service providers are based in Europe, India, Asia Pacific and North and South America.
Brazil Nature Tours and the Brazil Nature Tours Payments will need to share your information, including personal information, in order to ensure the adequate performance of our contract with you.
3.8 Social Media Platforms.
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 platforms, such as Facebook or Google, to generate leads, drive traffic to our websites or otherwise promote our products and services or the Brazil Nature Tours 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 platforms with which we may share your personal data are not controlled or supervised by Brazil Nature Tours. Therefore, any questions regarding how your social media platform service provider processes your personal data should be directed to such provider.
Please note that you may, at any time ask Brazil Nature Tours to cease processing your data for these direct marketing purposes by sending an e-mail to opt-out@Brazil Nature Tours.com.
3.10 Government Registration.
In jurisdictions where Brazil Nature Tours facilitates or requires a registration, notification, permit, or license application of a Host with a local governmental authority through the Brazil Nature Tours website in accordance with local law, we may share information of participating Hosts with the relevant authority, both during the application process and, if applicable, periodically thereafter, such as the Host’s full name and contact details, Accommodation address, tax identification number, Listing details, and number of nights booked.
3.13 Business Transfers.
3.14 Aggregated Data.
We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.
4. OTHER IMPORTANT INFORMATION
4.1 Analyzing your Communications. We may review, scan, or analyze your communications on the Brazil Nature Tours website for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, and customer support purposes. For example, as part of our fraud prevention efforts, we scan and analyze messages to mask contact information and references to other websites. In some cases, we may also scan, review, or analyze messages to debug, improve, and expand product offerings. We use automated methods where reasonably possible. However, occasionally we may need to manually review some communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools. We will not review, scan, or analyze your communications to send third party marketing messages to you, and we will not sell reviews or analyses of these communications. These activities are carried out based on Brazil Nature Tours’s legitimate interest in ensuring compliance with applicable laws and our Terms, preventing fraud, promoting safety, and improving and ensuring the adequate performance of our services.
5. THIRD PARTY PARTNERS & INTEGRATIONS
The Brazil Nature Tours website may contain links to third party websites or services, such as third party integrations, co-branded services, or third party-branded services (“Third Party Partners”). Brazil Nature Tours doesn’t own or control these Third Party Partners and when you interact with them, you may be providing information directly to the Third Party Partner, Brazil Nature Tours, or both. These Third Party Partners will have their own rules about the collection, use, and disclosure of information. We encourage you to review the privacy policies of the other websites you visit.
6. YOUR RIGHTS
You may exercise any of the rights described in this section before your applicable Brazil Nature Tours Data Controller and Payments Data Controller by sending an email to dpo@Brazil Nature Tours.com. Please note that we may ask you to verify your identity before taking further action on your request.
6.1 Rectification of Inaccurate or Incomplete Information.
You have the right to ask us to correct inaccurate or incomplete personal information concerning you (and which you cannot update yourself within our website).
6.3 Data Access and Portability.
In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).
6.4 Data Retention and Erasure.
We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you no longer want us to use your information to provide the Brazil Nature Tours website to you, you can request that we erase your personal information and close your Brazil Nature Tours Account. Please note that if you request the erasure of your personal information:
• We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend an Brazil Nature Tours Account for fraud or safety reasons, we may retain certain information from that Brazil Nature Tours Account to prevent that Member from opening a new Brazil Nature Tours Account in the future.
• We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, Brazil Nature Tours and Brazil Nature Tours Payments may keep some of your information for tax, legal reporting and auditing obligations.
• Information you have shared with others (e.g., Reviews, forum postings) may continue to be publicly visible on the Brazil Nature Tours website, even after your Brazil Nature Tours Account is cancelled. However, attribution of such information to you will be removed. Additionally, some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers.
• Because we maintain the Brazil Nature Tours website to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.
6.5 Withdrawing Consent and Restriction of Processing.
Where you have provided your consent to the processing of your personal information by Brazil Nature Tours you may withdraw your consent at any time by changing your Account settings or by sending a communication to Brazil Nature Tours specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing pursuant to Section 6.6 and pending the verification whether the legitimate grounds of Brazil Nature Tours override your own.
6.6 Objection to Processing.
In some jurisdictions, applicable law may entitle you to require Brazil Nature Tours and Brazil Nature Tours Payments not to process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing Brazil Nature Tours and/or Brazil Nature Tours Payments will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defence of legal claims.
Where your personal information is processed for direct marketing purposes, you may, at any time ask Brazil Nature Tours to cease processing your data for these direct marketing purposes by sending an e-mail to opt-out@Brazil Nature Tours.com.
6.7 Lodging Complaints. You have the right to lodge complaints about the data processing activities carried out by Brazil Nature Tours and Brazil Nature Tours Payments before the competent data protection authorities. If your Data Controller is Brazil Nature Tours Ireland or Brazil Nature Tours GSL, you have the right to file a complaint with its lead supervisory authority, the Irish Data Protection Commissioner. If your Payments Data Controller is Brazil Nature Tours Payments (UK) Ltd. with its lead supervisory authority, the Information Commissioner’s Office.
7. OPERATING GLOBALLY
7.1 EU-US & Swiss-US Privacy Shield.
Under the Privacy Shield Framework, Brazil Nature Tours and Brazil Nature Tours Payments are subject to the authority of the Federal Trade Commission. If you have any questions or concerns relating to our Privacy Shield certification, contact us at Brazil Nature Tours, Inc., Legal Department, 888 Brannan Street, San Francisco, CA 94103 or via email. If we are not able to resolve your concern, you may also contact your European Data Protection Authority or Commission or seek assistance from our designated Privacy Shield independent recourse mechanism, JAMS. In certain circumstances, you may also have the right to pursue binding arbitration through the Privacy Shield Framework, as described in Annex I to the Privacy Shield Principles.
7.2 Other Means to Ensure an Adequate Level of Data Protection.
If Brazil Nature Tours Ireland is the Data Controller and your information is shared with corporate affiliates or third party service providers outside the EEA, we have – prior to sharing your information with such corporate affiliate or third party service provider – established the necessary means to ensure an adequate level of data protection. This may be an adequacy decision of the European Commission confirming an adequate level of data protection in the respective non-EEA country or an agreement on the basis of the EU Model Clauses (a set of clauses issued by the European Commission). We will provide further information on the means to ensure an adequate level of data protection on request.
7.3 California & Vermont Residents.
Brazil Nature Tours Payments will not share information it collects about you with its affiliates or third parties (both financial and non-financial), except as required or permitted by your state’s law.
7.4 California Privacy Rights.
California law permits Members who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those third parties. See the “Contact” section for where to send such requests. Brazil Nature Tours and Brazil Nature Tours Payments do not share personal information with third parties for their own direct marketing purposes without your prior consent. Accordingly, you can prevent disclosure of your personal information to third parties for their direct marketing purposes by withholding consent.
We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls. If you know or have reason to believe that your Brazil Nature Tours Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your Brazil Nature Tours Account, please contact us following the instructions in the Contact Us section below.