1 INTRODUCTION Point EU, Inc. (“Point EU”) is a non-profit organization that enables and facilitates the provision of housing to persons in need in times of crisis and engages in related efforts to increase emergency preparedness and provide relief and support to impacted communities. We will often partner with other nonprofit organizations in pursuit of such efforts. The information that’s shared with us helps us to execute our mission. Your trust is important to us and we’re committed to protecting the privacy and security of your personal information. This privacy policy (“Privacy Policy”) describes how Point EU collects, uses, processes, and discloses your personal information. Some of the programs we facilitate may require users to create an account on the Point Platform or to make use of an existing account. When you use the Point Platform as part of Point EU's programs, the ways in which your information is collected, used, processed and disclosed is described in the Point Privacy Policy. Definitions If you see an undefined term in this Privacy Policy (such as “Point Platform”), it has the same definition as under the Point Privacy Policy. Company/ies responsible Point EU (“we”, “us”, “our”) is responsible for the processing of your information in connection with your use of the Point EU programs. To the extent that the processing of your information involves the use of the Point Platform (“Joint Processing”), Point EU and the relevant Point company listed in Schedule 1 of the Point Privacy Policy are responsible for your information under the Privacy Policy.
2 INFORMATION WE COLLECT Information You Give To Us. Point Information. In order to book a stay supported by Point EU, or to host a stay in support of Point EU on the Point Platform, users create an Point account or use an existing Point account. When you book or host an Point EU supported stay, Point will share certain information with us including your name, phone number, other Point profile information, Point usage information, Point listing information, and the details of your booking. Donations. When you make a donation to Point EU using Stripe we receive information including your name, email address and the amount of your donation. We automatically collect and log information about your device and use of Point EU. That information includes: IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages and features you’ve viewed or used. We may also collect this information from Point as it relates to your Point account. Cookies and Similar Technologies. We use cookies and other similar technologies when you use Point EU. To learn more, click here.
3 HOW WE USE THE INFORMATION WE COLLECT We may use, store, and process personal information to (1) provide, understand, improve, and develop the Point EU programs, (2) create and maintain a trusted and safer environment (such as to comply with our legal obligations and policies) and (3) provide, personalize, measure, and improve our advertising and marketing. Provide, Understand, Improve, and Develop the Point EU programs. We may use personal information such as to: enable you to access and use the Point EU programs, operate, protect, improve, and optimize the Point EU programs and experience, such as by performing analytics and conducting research, provide customer service, and send you service or support messages and updates. We process this personal information for these purposes given our legitimate interest in improving the Point EU programs and your experience with it. 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, comply with our legal obligations, resolve any disputes with any of our users and enforce our agreements with third parties, and enforce our policies. We process this personal information for these purposes given our legitimate interest in protecting the Point EU programs and to comply with applicable laws. 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 a newsletter, send you promotional messages, marketing, advertising, and other information about Point EU’s charitable programs and fundraising for those programs and social media advertising through social media platforms such as Facebook or Google, personalize, measure, and improve our advertising, and invite you to events. We will process your personal information for the purposes listed in this section given our legitimate interest in undertaking marketing activities to alert you to charitable programs and activities that may be of interest to you. SMS Terms for the United States For text messaging in the United States, by requesting, joining, agreeing to, enrolling in, signing up for, acknowledging, or otherwise consenting to receive one or more text messages (“Opt In”) or using an arrangement in which Point EU sends (or indicates that it may send, or receives a request that it send) one or more text messages (“Text Message Service”), you accept these SMS Terms for U.S. (“SMS Terms”), and consent to the handling of your personal information as described in the Point EU Privacy Policy. Message and data rates may apply. Point EU will use reasonable commercial efforts to deliver automated text messages to the mobile number you provide. Point EU is not liable for delayed or undelivered messages. By Opting In to a Text Message Service: You expressly authorize Point EU to use autodialer or non-autodialer technology to send text messages to the mobile phone number associated with your Opt In. You also authorize Point EU to include marketing content in any such messages. You do not have to Opt In or agree to Opt In as a condition of purchase. You consent to the use of an electronic record to document your Opt In. To withdraw that consent, reply STOP, or contact us via the methods described in this Privacy Policy. If you withdraw your consent, certain features of our service may not be available to you. You confirm that you are the current subscriber to the Opted In mobile phone number or that you are the customary user of that number on a family or business plan and that you are authorized to Opt In. For additional help in relation to a text message, you may text HELP in response to a message or contact us. Your Choices You have choices on the promotional messages that you choose to receive. You can limit the information you provide to Point EU. Participation in promotions and marketing programs is voluntary. To opt-out of marketing emails, simply click the link labeled “unsubscribe” at the bottom of any marketing email we send you.
4 SHARING & DISCLOSURE Sharing With Your Consent or at Your Direction. Where you provide consent, we share your information as described at the time of consent. Advertising and Social Media 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 the Point EU programs. These processing activities are based on our legitimate interest in undertaking marketing activities to alert you to charitable programs or activities that may be of interest to you. The social media platforms with which we may share your personal information are not controlled or supervised by Point EU. Therefore, any questions regarding how your social media platform service provider processes your personal information should be directed to that provider. Please note that you may, at any time ask Point EU to cease processing your data for these direct marketing purposes by sending an e-mail to pointapp.eu@gmail.com. Compliance with Law, Responding to Legal Requests, Preventing Harm and Protection of our Rights. Point EU 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 Point EU, (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) to enforce and administer our agreements with users, or (v) to protect the rights, property or personal safety of Point EU, its employees, its users, or members of the public. 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 Point EU services secure, preventing harm or crime, enforcing or defending legal rights, and prevention of tax fraud or preventing damage. Where appropriate, we may notify users 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 Point EU’s property, its users and the Point EU services. In instances where we comply with legal requests without notice for these reasons, we may attempt to notify that user about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so. Service Providers. In addition to Point providing the Point Platform, Point EU also uses a variety of third-party service providers to help us provide services related to the Point EU programs. Service providers may be located inside or outside of the European Economic Area (“EEA”). These include financial and legal service providers and philanthropy and fundraising consultants. Business Transfers. If Point EU undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence). In this event, we will notify you before your personal information is transferred and becomes subject to a different privacy policy. 5 YOUR RIGHTS Consistent with applicable law, you may exercise the rights described in this section. For any personal information that was collected and processed via the Point Platform, you should exercise your data rights directly via the Point Platform. For any personal information collected and processed by Point EU, you may exercise your rights by contacting us directly via email at DSR@Point EU. Please note that we may ask you to verify your identity before taking further action on your request. Data Access and Portability. In some jurisdictions, applicable law may entitle you to request certain 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). Rectification of Inaccurate or Incomplete Information. You have the right to ask us to correct inaccurate or incomplete personal information about you. Data Retention and Erasure. You have the right, in certain cases, to ask us to delete your information, provided there are valid grounds for doing so and subject to applicable law. Withdrawing Consent and Restriction of Processing. If we are processing your personal information based on your consent you may withdraw your consent at any time by sending a communication to Point EU 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 and pending the verification whether the legitimate grounds of Point EU override your own. Objection to Processing. In some jurisdictions, applicable law may entitle you to require Point EU not to process your personal information for certain specific purposes where such processing is based on legitimate interest. If you object to such processing, Point EU 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. Lodging Complaints. You have the right to lodge complaints about our data processing activities by filing a complaint with our Data Protection Officer, who can be reached by the “Contact Us” section below, or with a supervisory authority. 6 OPERATING GLOBALLY & INTERNATIONAL TRANSFERS Where we transfer, store, and process your personal information outside of the EEA we have ensured that appropriate safeguards are in place to ensure an adequate level of data protection. We rely on Standard Contractual Clause approved by the European Commission to transfer data from the EEA, Switzerland and other countries outside of where you live. You may request a copy of the Standard Contractual Clauses by contacting us at DSR@Point EU. 7 SECURITY While no organization can guarantee perfect security, we are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. 8 THIRD PARTY PARTNERS & INTEGRATIONS Parts of Point EU may link to third-party services not owned or controlled by Point EU, such as the Point Platform or PayPal. Use of these services is subject to the privacy policies of those providers, such as the Point Terms of Service, the Point Privacy Policy, the PayPal User Agreement, and the PayPal Privacy Statement. Point EU does not own or control these third parties and when you interact with them you are providing your information to them. 9 CHANGES TO THIS PRIVACY POLICY We reserve the right to modify this Privacy Policy pursuant to applicable law. If we make material changes to this Privacy Policy, we will post the revised Privacy Policy on the Point EU website and update the “Last Updated” date at the top of this Privacy Policy. If we make any material changes to this Privacy Policy we may also provide you with notice of the modification by email at least thirty (30) days before the effective date. 10 CONTACT US If you have any questions or complaints about this Privacy Policy or Point EU’s information handling practices, you may email us at the email addresses provided in the relevant sections above or contact us at: Point EU. Vārnu iela 12-4, Rīga, LV-1009. Kemperplatz 1 Mitte D, 10785 Berlin, Germany.