StudentRoomStay International Corporation (“SRS”, “We”, “us” or “our”) is committed to protecting the privacy and personal information that we receive from you.
Who We Are; How To Contact Us.
Some laws (like GDPR) distinguish between a “controller” and a “processor” (or similar terms). We note that we are a “controller” for those services where we make decisions on how personal information is used in connection with our services, and we are a “processor” for those services where we only use personal information as allowed by users or relevant third parties.
If you wish to contact SRS that is a controller or a processor for the Services relevant to you, please contact us at the email mentioned above.
What Information about you do we collect?
We collect your personal information when you access or use SRS Website, register an Account, submit a query via our online “contact us” form, or otherwise email or call us. We also automatically collect certain information from you through automated technologies such as cookies when you access to or use SRS Website. We may also receive your information from our affiliated companies, our business partners or other third parties if you have given them consent to do so (e.g. an education agent).
You may provide us with two types of information: (1) personal information that you knowingly choose to disclose, which is collected on an individual basis, and (2) general user information that does not contain personally identifiable information, which is collected automatically when you use SRS Website. If you choose not to provide us with requested information, you may not be able to access or use some part of SRS Website or certain services.
Information that you choose to provide
For certain activities, such as when you register an Account, upload Member Content, or contact us directly, you may provide some or all of the following personal information:
- Account Information. When you sign up for an SRS Account, we require certain information such as your first name, last name, email address, and date of birth.
- Profile and Listing Information. To use certain features of SRS Website (such as booking or creating a listing), we may ask you to provide additional information, which may include but not limited your address, phone number, and a profile picture.
- Additional Profile Information. You may choose to provide additional information as part of your Account 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.
- Payment Information. To use certain features of SRS Website (such as booking or creating a listing), we may require you to provide certain financial information (like your bank account or credit card information) in order to facilitate the processing of payments.
- Member Content. You may list an Accommodation, post Reviews, Ratings, comments, or questions, or otherwise communicate with SRS or other Members on or through SRS Website. All the texts, photographs, videos, audios, and other information and content that you choose to upload, publish, transmit, or otherwise submit on or through SRS Website are collectively referred to as “Member Content”.
Information We Collect Automatically.
When you use SRS Website, we automatically collect certain information from you about the services you use and how you use them, including without limitation the following information:
- Geo-location Information. When you use certain features of SRS 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. SRS 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 SRS Website such as the pages or content you view, your searches for Accommodations, bookings you have made, and other actions on SRS Website.
- Log Data and Device Information. We automatically collect log data and device information when you access and use SRS Website, even if you have not created an SRS Account or logged in. That information includes, among other things: details about how you’ve used SRS 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 SRS Website.
How do we use your personal information?
We may use your personal information we collect for the following purposes:
- to provide, deliver, analyze, and administer SRS Website and our services (including in connection with the performance of a contract).
- to process transactions related to our services and administer accounts or profiles related to you (including without limitation registrations, listings, bookings, billing, and payments).
- for internal research and development purposes for new content, features, products, and services, and to improve, test, and enhance the features and functions of current SRS Website.
- to use Member Content as part of our advertising and marketing campaigns to promote SRS Website or our services.
- to personalize and make recommendations related to our services and other offerings.
- to contact and communicate with you in connection with SRS Website, our services or other notifications, programs, events, or updates that you may have registered for or be interested in.
- to send you offers, advertising, and marketing materials, including to provide personalized advertising to you.
- to comply with your instructions or to fulfill other, specified purposes for which you have given your consent.
- to detect and prevent fraud, abuse, and other illegal activities on SRS Website to ensure the security and protection of all users and others.
- to exercise our rights and to protect our and others’ rights and/or property, including to take action against those that seek to violate or abuse our services.
- for any other purposes disclosed to you at the time we collect your information or pursuant to your consent.
HOW WE SHARE PERSONAL INFORMATION?
We may share your personal information with the following recipients:
- SRS Affiliates. We may share your personal information with our affiliated companies and their respective officers, employees, consultants and/or contractors.
- Other Members. As part of providing our services to you, we may need to share certain information about you with other Members. If you are a Student, when you submit a booking request, certain information is shared with the Provider, including your profile, full name, and other information you agree to share. When your booking is confirmed, we will disclose additional information to the Provider to assist with coordinating the trip, like your phone number. If you are a Provider, when you have a confirmed booking, certain information is shared with the Student who booked the Accommodation, such as your profile, full name, phone number, and Accommodation address.
- Service providers. We may share your personal information with our service providers to jointly offer, provide, deliver, analyze, administer, improve, and personalize products or services. Some of our service providers, or the services they provide (like cloud-based storage solutions), may be based outside of the United States. If your personal information is transferred outside of the United States, we will take reasonable measures and have adequate procedures in place to ensure the security of your personal information in accordance with the requirements of the applicable data protection laws.
- Business Partners. We may share information from or about you with our business partners, including but not limited to for direct advertising or marketing purposes. For instance, to promote SRS Website, we may display parts of SRS Website (e.g., the listing of Accommodations) on sites operated by our business partners, using technologies such as widgets or APIs. If your Accommodations are displayed on a business partner’s site, information from your public profile page may also be displayed.
- Counterparties in Corporate Transactions. We may choose to buy or sell assets, or merge with or into other companies. In such transactions, your personal information is typically one of the business assets that would be transferred. Also, if SRS (or its assets) are acquired, or if SRS goes out of business, enter bankruptcy, or go through some other change of control, your personal information would be one of the assets transferred to or acquired by a third party.
We may disclose your personal information at the request of law enforcement or government agencies or in response to subpoenas, court orders, or other legal process to establish, protect, or exercise our legal or other rights or to defend against a legal claim or as otherwise required or allowed by law. We may disclose your personal information in order to protect the rights, property, or safety of a user or any other person. We may disclose your personal information to investigate or prevent a violation by you of any contractual or other relationship with us or your illegal or harmful activity.
We may aggregate or de-identify your personal information that we receive. We may use such aggregated non-personally identifying information for any legitimate purposes.
Cookies and Similar Technologies.
Our software may issue ‘cookies’ (small text files) to your device when you access and use SRS Website, and you will be asked to consent to this at the time (e.g. when you first visit our website). Cookies do not affect your privacy and security since a cookie cannot read data off your system or read cookie files created by other sites.
You can set your system not to accept cookies if you wish (for example by changing your browser settings so cookies are not accepted), however please note that some of SRS Website features may not function if you remove cookies from your system.
Web beacons are very small images or small pieces of data embedded in images, also known as “pixel tags” or “clear GIFs,” that can recognize cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar information from your computer or device. We use web beacons to tell us what parts of SRS Website customers have visited or to measure the effectiveness of searches customers perform on SRS Website. Web beacons also enable us to send email messages in a format that customers can read. And they tell us whether emails have been opened to ensure that we’re sending only messages that are of interest to our customers. We may use this information to reduce or eliminate messages sent to a customer.
Publicly Displayed Information is Public.
You acknowledge and agree that the Member Content that you submit is visible to the general public, which may include without limitation the following:
- Your public profile page, such as your first name, your description, and city.
- Information about the Accommodation, such as the location, description, calendar availability, and other information Provider chooses to share.
- Member’s Reviews and Ratings.
- Content you submit when you engage in other public activities on SRS Website, such as content submitted in a community or discussion forum or social media posts.
Information you share publicly on SRS Website is visible to the public, and may be read, collected, or used by other users. Such information 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 change such public available information, 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. You should use caution in disclosing personal information while engaging in such public activities on SRS Website. SRS is not responsible for the personally identifiable information or other confidential information you choose to include in your Member Content.
Privacy of Children.
SRS takes precautions—including administrative, technical, and physical measures—to safeguard your personal information against loss, theft, and misuse, as well as unauthorized access, disclosure, alteration, and destruction. However, no data transmission or data storage over the Internet can be guaranteed to be completely secure. Accordingly, we cannot ensure or warrant the security of any information that you submit to us, so you do so at your own risk.
Because many users tend to use SRS Website and our services at different points of their student or accommodation needs, we retain your information for continued service and convenience purposes until you advise us not to do so (Please see Section “how to contact us” for our contact information). Notwithstanding the foregoing, we may retain personal information in order to comply with applicable laws, keep accurate records, resolve disputes, prevent fraud, enforce our Terms and Conditions or other agreements, or for any other legally permissible purpose.
We offer you choices regarding the collection, use, and sharing of your personal information.
If you register an Account with us, you may modify, update or delete your personal information by visiting your Account where you will have the opportunity to access and revise certain of your personally identifiable information, and to update your preferences regarding what information you want to receive from us. You may request deletion of your account information by us, but please note that we may be required (by law or otherwise) to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request, only after we have fulfilled such requirements). When we delete account information, it will be deleted from the active database, but may remain in our archives.
In certain circumstances, local data protection laws may give you certain rights with respect to personal information if you are located in or are a resident of that state, country, or territory. We will honor such rights to the extent that these rights have been granted to you and apply to you under such applicable data protection laws.
Your Rights as a California Resident
If you are a California resident, you have the following rights (subject to certain exceptions) regarding your personal information under California Consumer Privacy Act (“CCPA”):
- Right to Disclosure of Information. You have the right to request that we disclose certain information regarding our practices with respect to your personal information, specifically (i) the categories of personal information we have collected about you in the last 12 months, (ii) the categories of sources for the personal information we have collected about you in the last 12 months, (iii) our business or commercial purpose for collecting that personal information, (iv) the categories of third parties with whom we share that personal information, and (v) the specific pieces of personal information we collected about you in the past 12 months.
- Right to Deletion. You have the right to request that we delete all personal information that we collected from you and retained, subject to certain exceptions.
- Right to Opt-Out of Sale of Personal Information. SRS does not and will not sell your personal information. While SRS does not sell your personal information, pursuant to applicable law, you may request that your information not be sold in the future.
- Right against Discrimination. You may exercise your rights under the CCPA without discrimination.
To exercise the rights above, you must submit a verifiable request to firstname.lastname@example.org. Please note that if you choose to make a CCPA request, we will require certain information in order to verify your identity, including without limitation your name, account information, address, and telephone number.
California residents can also request a list of all the third parties to which we have disclosed certain personal information (as defined by California’s Shine the Light law) during the preceding year for those third parties’ direct marketing purposes. If you would like to make such a request, please contact us at email@example.com.
Your Rights as a EEA Resident
If you are a resident in the European Economic Area, you may have the following rights:
- Right of subject access: The right to make a written request for details of your personal information and a copy of that personal information;
- Right to rectification: The right to have inaccurate information about you corrected or removed;
- Right to erasure (“right to be forgotten”): The right to have certain personal information about you erased;
- Right to restriction of processing: The right to request that your personal information is only used for restricted purposes;
- Right to opt out of marketing: You can manage your marketing preferences by unsubscribe links found in the communications you receive from us or by visiting the applicable preference center;
- Right to object: The right to object to processing of your personal information in cases where our processing is based on the performance of a task carried out in the public interest or we have let you know the processing is necessary for our or a third party’s legitimate interests;
- Right to data portability: The right to ask for the personal information you have made available to us to be transferred to you or a third party in machine-readable format;
- Right to withdraw consent: The right to withdraw any consent you have previously given us to handle your personal information. If you withdraw your consent, this will not affect the lawfulness of our use of your personal information prior to the withdrawal of your consent.
Links To Third-Party Websites or Services.