Legal, Terms and Conditions & Privacy Policy

HomeToGo GmbH, represented by its managing directors Dr. Patrick Andrä, Wolfgang Heigl, Nils Regge

Perleberger Str. 42a

10559 Berlin

Germany

Registered at Local Court Berlin-Charlottenburg, HRB 155381 B

VAT: DE293800056

Phone: +49 (0)30-20847396

Fax: +49 (0)30-208473260

Email: info@hometogo.com.hk

Responsible for contents according to § 55 paragraph 2 RStV: Dr. Patrick Andrä

1. General

(1) The HomeToGo GmbH, Perleberger Str. 42a, 10559 Berlin (hereafter referred to as “HomeToGo”) provides a technical interface that enables commercial and private providers of accommodation (hereafter referred to as “Providers”), to place offers of holiday apartment or overnight stay accommodation in a database that can be linked with the Providers’ various booking websites. Users seeking accommodation (hereafter referred to as “Users”) shall be granted access to this database via www.hometogo.com.hk and/or other websites operated by HomeToGo and directed to the website of the Provider of the holiday apartment or overnight accommodation in order to carry out the booking process.

(2) These terms and conditions regulate the use of the database via the aforementioned HomeToGo websites and include access from mobile websites and any application (“App”) developed by HomeToGo as well as any portals or applications for mobile devices provided by third parties. These terms and conditions apply exclusively; HomeToGo rejects the application of any alternative terms and conditions imposed by the User.

(3) The usage of all websites operated by HomeToGo and the provided data bases („Our Website“) is only permitted for private use. A commercial usage of Our Website is explicitly prohibited. Our Website is not to be used for false, fraudulent or speculative reservations, neither for reservations to cover future demand. By using Our Website you confirm to abstain from the following actions and measures without previous written consent by HomeToGo:

- To access our website by using a manual or automated process that exceeds the purpose of personal use or the inclusion of HomeToGo into a search index. The use of automated systems or a software to extract data from Our Website (so called „screen scraping“), is prohibited for non-commercial and commercial purposes.

- To infringe on existing restrictions in robot-exclusion-headers on Our Website or to circumvent measures that restrict or prevent the access to Our Website.

- To use a device, software or program that affects or tries to affect the regular functionality of Our Website, or to carry out an act that inappropriately strains our servers, computer or network.

HomeToGo reserves the right to end, suspend or limit the access to all or specific components of Our Website at our own discretion without previous announcement and under exclusion of any liability.

2. HomeToGo services for users

(1) HomeToGo provides a targeted search function that enables Users to identify the most suitable Provider’s offer in the database and then forwards the User to that Provider’s site or puts the User directly in contact with the Provider. HomeToGo is therefore not the service provider for any of these websites. Specifically, the use of HomeToGo services does not give rise to a package travel contract with HomeToGo in the sense of § 651a German Civil Code (BGB).

(2) Where a search returns a large number of results, the results displayed shall be limited to a specific amount to guarantee search functionality.

(3) Users may use the HomeToGo database free of charge.

(4) HomeToGo advises that offers posted by Providers may be subject to a commission in the event of a successful booking contract. The manner in which this contract between the User and the Provider is formed and any content within such contract must be consistent with the law and with any agreement between the two parties concerned.

(5) HomeToGo may permit its services to be provided by third parties.

(6) As HomeToGo provides its services free of charge, the User has no right to damages or the enforcement of the contract. HomeToGo retains the right to cancel the offer at any time without notice.

3. HomeToGo is not liable for offers or subsequent booking contracts

(1) HomeToGo is solely the technical services provider, only enabling a search for suitable offers. HomeToGo will not publish their own offers on the aforementioned websites, nor does HomeToGo assume any liability for any offers made. The Provider carries sole responsibility for all and any offers posted on the aforementioned websites and any other websites linked to by HomeToGo, along with any related declarations of intent. HomeToGo does not assume any liability for the accuracy or currency of the information posted by the Provider, particularly where this information is stored on a mobile device.

(2) Any contracts or bookings of overnight stays and/or use of holiday apartments exist solely between the Provider and the User. HomeToGo is exempt from any contractual regulation, agreement or claim existing between the User and any external booking agent. Bookings shall be governed exclusively by the General Terms and Conditions of the service provider or travel agency, particularly with regard to cancellation and withdrawal. The booking service provider or travel agency remains the sole point of contact for booking and payment processes, as well as any questions relating to that contract. HomeToGo is not able to provide any information on these matters.

(3) The previous paragraphs (1) and (2) remain effective provided that and if HomeToGo captures bookings or booking inquiries or the associated data and information itself, for the purpose of the transmission of a booking or booking inquiry to the provider (e.g. within the scope of express bookings or inquiry forms).

(4) Offers will be updated at least once daily via a technical interface.

4. Prices

(1) The prices indicated in the offer(s) shall be determined by the Provider and communicated to HomeToGo at least once daily.

(2) Offer price is understood to be to the final price for the accommodation, however responsibility for ensuring that prices are appropriate and accurate rests with the Provider. While HomeToGo endeavours to present the total cost of the offer, additional charges may be levied by the Provider’s booking website.

5. Liability

(1) HomeToGo is not liable for the accuracy, quality, completeness, reliability or credibility of Provider created content and/or offers. In particular, HomeToGo does not provide any recommendation or further information regarding the choice of Provider and/or offer.

(2) HomeToGo is not liable for any technical disruption where the cause lies outside of HomeToGo’s field of responsibility, or caused by force majeure.

(3) HomeToGo does not guarantee uninterrupted access to data. HomeToGo retains the right to conduct technical maintenance as required for as long as necessary.

(4) HomeToGo is only liable for damages, regardless of legal basis, caused by deliberate intent and gross negligence. There is no liability for simple negligence except in cases of injury to life, body or health and for claims arising under the Product Liability Act.

(5) Limitations to HomeToGo’s liability also apply to the personal liability of all employees, representatives and agents.

6. User accounts

(1) For some services offered on the aforementioned HomeToGo websites, a so-called user account is required. Please follow the respective instructions of HomeToGo in the course of the registration.

(2) A user account can be set up with the personal e-mail address or the personal profile of a social network (e.g., Facebook, Google). A user account is also created when you use your email address to register for other HomeToGo features via email and confirm your email address in the process.

(3) If you create your account using a personal profile from a 3rd party service (e.g. Facebook, Google) you give us permission to access and use your information from that service as permitted by that service, and to store your log-in token for that service. You find further information about connecting via 3 rd party services in our Privacy Policy.

(4) Changes to User information can be made in the User Profile. Users may also register via “Facebook Connect”. The data required for successful registration will be transferred from the User’s Facebook account

(5) The user account can be accessed from any device. The user is given a personal login link via email or can use the personal profile of a social network (eg Facebook, Google) used for the registration to login.

(6) HomeToGo reserves the right to temporarily block user accounts, to irrevocably delete them, or to take other necessary measures if the user violates applicable laws, these terms of use or other applicable terms of contract.

(7) The user account can be logged out at any time from the aforementioned websites of HomeToGo by using the following link: www.hometogo.com.hk/account/logout. The deletion of a user account can be caused by an e-mail to info@hometogo.com.hk.

7. Privacy

(1) HomeToGo gives the highest priority to protecting User information. For further information please refer to the HomeToGo Privacy Policy.

(2) Personal information is only provided, processed and utilised with the consent of the User or where the collection, processing or use of such data is permitted by law.

8. Changes to GTC

(1) HomeToGo retains the right to make changes to the GTC with appropriate notice of at least six weeks. In the case of any changes, HomeToGo shall announce the changes on the website, and nominate the date at which the changes are to enter into effect.

(2) Where the User does not reject these changes within six weeks from the announcement date, the amended GTC shall be deemed accepted by the User. Users shall be reminded of this in the Changes to Conditions announcement.

9. Final conditions

(1) The laws of the Federal Republic of Germany apply, excluding the UN Convention on the International Sale of Goods (CISG). The place of execution and the court of jurisdiction for all disputes arising from or related to this contract with traders, legal entities under public law or public bodies is Berlin.

(2) Please note that even if our services including these General Terms and Conditions are offered and outlined in English, in any case of any deviation between the English and the German version, the German language version will prevail. The German Version can be found under the following link: https://www.hometogo.de/impressum/#agb

(3) Should one of these General Terms and Conditions become invalid in whole or in part, or unworkable under law, this does not effect the validity of the remainder of the contract.

Data privacy is a matter of trust, and your trust matters to HomeToGo. It is therefore important to us that your personal data is protected and that its collection, processing and use in relation to HomeToGo's services in our app and on our website hometogo.com.hk complies with the law. In this Policy, we want to tell you about how we collect and use data, in order to give you an overview of how your personal data will be used.

1. Overview

The following Privacy Policy contains information about the way and extent to which personal data is processed by HomeToGo. Personal data is information that can be directly or indirectly attributed to or associated with you personally, such as your name or your email address.

2. Name and contact details of the controller responsible for processing and the company's Data Protection Officer

This Privacy Policy applies to the data processing performed by HomeToGo GmbH, Perleberger Str. 42a, 10559 Berlin (the "controller", hereinafter "HomeToGo"), to be contacted at info@hometogo.com.hk, and for the following website or application: www.hometogo.com.hk.

The company Data Protection Officer of HomeToGo can be reached at datenschutzbeauftragter@datenschutzexperte.de (Datenschutzexperte.de, PROLIANCE GmbH, Leopoldstr. 21, 80802 Munich, Germany).

3. The purposes for which data is processed, the legal basis and legitimate interests pursued by HomeToGo or a third party, as well as categories of recipients

3.1. Accessing our website/application

When you access our website/application, the browser used on your device automatically sends information to the server of our website/application and temporarily stores it in what is known as a log file. We have no control over this. The following information will also be collected without any action on your part and be stored until it is automatically deleted:

• the IP address of the requesting internet-enabled device
• the date and time of access
• the name and URL of the retrieved file
• the website/application from which access took place (the Referrer URL)
• the browser you are using, and potentially the operating system of your internet-enabled computer, as well as the name of your access provider
• the device used (e.g., a desktop computer or a smartphone)
• the language of the browser you are using

The legal basis for processing your IP address is Article 6 (1) (f) of the General Data Processing Regulation (GDPR). Our legitimate interest is based on the purposes of data collection listed below. We would like to point out that we are unable to draw any direct conclusions regarding your identity from the data that is collected, and that we refrain from doing so.

We use the IP address of your device and the other data listed above for the following purposes:

• ensuring that a trouble-free connection is established
• ensuring the comfortable use of our website/application
• the evaluation of system security and stability

The data is stored for a period of up to 7 days and is then deleted automatically. We also use what are known as cookies for our website/application, as well as tracking tools, targeting methods and social media plug-ins. The exact procedures used and how your data are used for this purpose are explained in more detail below.

3.2. Creating and using a user account; bookings, booking inquiries and HomeToGo Money-Back Guarantee

3.2.1. Creating an account

When you create a user account with us, we process personal data in the following alternative manner:

• when logging in using Google (social login), your Gmail address and the information transmitted from your Google account (names, profile picture, link to your Google account and top-level domain, gender and hosted domain)
• when logging in using Facebook (social login: Facebook Connect), your email address and the public information from your Facebook account (names, profile picture, age range, gender, language, country and other public information)
• when logging in using your email, your email address

A user account is also created when you enter your email address in order to receive separate offers by email and subsequently confirm that you wish to receive the offers. Likewise, a user account is created when you enter your email address and then make a booking or booking inquiry through our website (see section 3.2.2.), or if you choose the HomeToGo Money-Back Guarantee (see section 3.3.). These services require the setup of a user account for technical reasons, storing email address, name and travel dates.

Each time you log in, technical information is stored about your device and your browser, as well as information about your searches. This helps us to improve your overall user experience on the website, as well as the overall services.

The legal basis for this is Article 6 (1) (b) and (f) of the GDPR. You provide us with data based on the contractual relationship between you and us. Our legitimation is also derived from the protection of your identity and the prevention of fraudulent activity.

We will delete the collected data no later than your termination of our platform’s usage contract.

3.2.2. Bookings and booking inquiries

We do not offer travel services ourselves. Rather, we enable you to book travel services offered by our partners.

When a booking inquiry is received, we collect the following data solely in order to forward it to our partners:

• the desired arrival and departure dates
• your first and last name
• the number of guests
• your email address
• (optionally) your message to the landlord

When you make a booking, we collect the following data solely in order to forward it to our partners:

• the arrival and departure dates
• your first and last name
• the number of guests
• your address
• your email address
• your phone number
• (optionally) selected extras
• the payment method, whereby payment processing is performed by Datatrans payment service (Datatrans AG, Kreuzbühlstrasse 26, 8008 Zurich, Switzerland), with whom we have concluded a data processing agreement

With the exception of the email address, name and travel dates, all of the aforementioned data will be deleted by us after it has been forwarded to the respective partner.

The collection of the aforementioned data and its transmission to our partners is a pre-contractual step that is required to enter into the contract with your respective partner (Article 6 (1) (b) GDPR).

3.3. Creating an account with HomeToGo Money-Back Guarantee

If you choose the HomeToGo Money-Back Guarantee, a user account is automatically created. The HomeToGo Money-Back Guarantee is an insurance provided by AWP P&C S.A. (Allianz Global Assistance, hereinafter “insurer”) with whom we have concluded a group insurance contract.

To record you and your fellow travelers as beneficiaries, the following data are collected and passed on to the insurance intermediary, Kasko Germany UG:

• the arrival and departure dates
• your first and last name
• your address
• your email address
• your phone number
• booking date
• booking number

We only store the data for the purpose of processing the insurance contract for the duration of the insurer’s contractual obligation towards you as the beneficiary. Legal basis is Article 6 (1) (b) GDPR.

3.4. Social logins (logging in with Facebook or Google)

3.4.1. Facebook Connect

When you log in through Facebook Connect, a direct connection is created to the servers at Facebook, 1601 South California Avenue, Palo Alto, CA 94304, USA ("Facebook"). Facebook detects that you have used your login information from HomeToGo as part of this process.

If you have expressly given your consent to Facebook pursuant to Article 6 (1) (a) of the GDPR, your personal data will be transmitted to us as part of the registration process via the social login. We use the following information from the transmitted data, which is stored by us until it is automatically deleted:

·      your email address

·      your Facebook profile name (first and last name)

·      the profile and wallpaper image you use on Facebook

·      your age group (over 18, over 21 years old)

·      a link to your Facebook account

·      your gender

·      the top-level domain of your logged-in Facebook account

·      the time zone in which you are on Facebook

This data is used to

·      identify you as our contractual partner

·      set up your user account

·      check the entered data for plausibility

The legal basis for the use of this data is Article 6 (1) (b) GDPR. Using this data enables us to fulfill our contractual obligations which arise from our Terms of Service (Article 6 (1) (b) GDPR). We will delete the collected data no later than your termination of our platform’s usage contract.

You can block the connection within your Facebook account.

Please refer to Facebook’s privacy policy for details regarding the purpose and scope of the data collection and further processing and use of the data by your service provider, as well as regarding your associated rights and the settings options you can use to protect your privacy (https://www.facebook.com/about/privacy/).

3.4.2. Logging in with Google

When you log in with Google by selecting "G continue with Google", a direct connection is established with the servers of Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA ("Google"). Google detects that you have used your login information from HomeToGo as part of this process. We do not obtain your Google Account information. Google then informs you that data from your Google Account will be made available to us and indicates the specific data in question.

Registration with and the use of Google are governed by Google's privacy policy and terms of service (https://policies.google.com/privacy?hl).

If you have expressly given your consent to Google pursuant to Article 6 (1) (a) of the GDPR, your personal data will be transmitted to us as part of the registration process via Google. We use the following information from the transmitted data, which is stored by us until it is automatically deleted:

·      your email address

·      your name on your Google account (first and last name)

·      the profile image (or the avatar) used on Google

·      a link to your Google account

·      your gender

·      the top-level domain of your logged-in Google account

·      the user domain you manage on Google (hosted domain, HD)

This data is used to

·      enable us to identify you as our contractual partner

·      set up your user account

·      check the entered data for plausibility

The legal basis for the use of this data is Article 6 (1) (b) GDPR. Using this data enables us to fulfill our contractual obligations which arise from our Terms of Service (Article 6 (1) (b) GDPR). We will delete the collected data no later than your termination of our platform’s usage contract.

You can block the connection within your Google account.

Please refer to Google’s privacy policy for details regarding the purpose and scope of the data collection and further processing and use of the data by Google, as well as regarding your associated rights and the settings options you can use to protect your privacy (https://policies.google.com/privacy?hl).

3.5. Data processing for advertising purposes

3.5.1. Newsletter

On our website, we offer you the opportunity to sign up for our newsletter. In order to be sure that no errors have occurred when entering your email address, we use what is known as the double opt-in process: after you have entered your email address in the registration field, we send you a confirmation link. Your email will only be added to our mailing list after you click on this confirmation link. You can revoke your consent provided in this manner at any time with effect for the future. To do so, you need only click the unsubscribe link.

3.5.2. Product recommendations

We send you emails which contain product recommendations. You will receive these product recommendations regardless of whether you have subscribed to a newsletter. We do so in order to provide you with information about products from our offerings that may interest you based on your recent searches.

If you do not want to receive product recommendations from us, you can let us know at any time. You can find our contact details under section 2. Naturally, you will also find an unsubscribe link in every email.

3.5.3. Interest-based advertising

In order for you to receive information that is likely to be of interest to you, we categorize your user profile. To do so, we use information about your searches to customize the newsletter articles and promotional emails we send you. The goal is to send you advertising that is oriented towards your actual needs and to avoid sending unnecessary advertising.

The legal basis for the aforementioned processing is Article 6 (1) (f) GDPR. Processing existing customer data this way for advertising purposes is deemed to be a legitimate interest.

3.5.4. Right to object

You have the right, at any time and at no charge, to object to data processing for the aforementioned purposes, separately for each respective communication channel, and with effect for the future. To do so, you need only send an email to info@hometogo.com.hk or send a letter to the HomeToGo address mentioned in section 2 above.

In the event that you object, the relevant contact address will be blocked for further promotional processing. We point out that, in exceptional cases, advertising material may temporarily continue to be sent to you even after your objection has been received. This is due to technical reasons related to the lead time required for advertisements and does not mean that your objection will not be observed by us. Thank you for your understanding.

3.6. Cookies – general information

We use cookies on our website on the basis of Article 6 (1) (f) GDPR. Our interest in optimizing our website is deemed to be legitimate within the meaning of the aforementioned provision.

Cookies are small files that your browser automatically creates and that are stored on your device (laptop, tablet, smartphone, etc.) when you visit our website or use our app. Cookies do not harm your device, do not contain viruses, Trojans or other malicious software. The information stored in the cookie is tied to the specific device used. However, this does not mean that we are immediately aware of your identity. In part, cookies are used to make the use of our service more pleasant for you. For example, we use what are known as session cookies to detect that you have already visited individual pages on our website or that you have already logged in to your user account. These are automatically deleted after you leave our website. In addition, to ensure user-friendliness we also use temporary cookies, which are stored on your device for a specific period of time. If you visit our website again to use our services, it is automatically detected that you have already visited us, as well as what information you entered and the settings you used, so that you do not have to reenter them.

If you already have an account and are logged in or activate the "Stay logged in" feature, the information stored in cookies will be added to your user account.

On the other hand, we use cookies to statistically record the use of our website, to optimize our services, and to display information tailored to your specific needs. These cookies enable us to automatically detect that you have previously visited us when you return to our website. These cookies are automatically deleted after a defined period of time. Most browsers accept cookies automatically. However, you can configure your browser so that no cookies are stored on your computer or to make sure that a message always appears before a new cookie is created. However, disabling cookies completely may mean that you will not be able to use all the features of our website. The storage period of cookies depends on their purpose and therefore varies.

3.7. Analytical tools

In order to customize and continuously optimize our websites in line with users’ needs, we deploy tools on the basis of Article 6 (1) (f) GDPR which permit us to analyze the use of our website.

3.7.1. Google Analytics

We use Google Analytics, a web analytics service provided by Google. In doing so, pseudonymized usage profiles are created and cookies are used. The information generated by the cookie about your use of this website, e.g.

• browser type/version
• operating system used
• Referrer URL (the previously visited page)
• hostname of the accessing computer (IP address)
• time of server request

is transmitted to a Google server in the US and stored there. Google complies with the Privacy Policy of the US Privacy Shield and is registered with the U.S. Department of Commerce's US Privacy Shield Program. In addition, we have entered into a data processing agreement for the use of Google Analytics. Under this agreement, Google assures that Google processes data in accordance with the General Data Protection Regulation and ensures the protection of the data subject's rights.

The information is used to evaluate the use of the website, to compile reports on the activity on the website, and to provide other services related to the use of the website and internet usage for the purposes of market research and to customize the design of these websites in line with the needs of users. This information may also be transferred to third parties if required by law or if third parties are contracted to process this data. Under no circumstances will your IP address be combined with any other data from Google. The IP addresses are anonymized, which means that it is not possible to identify specific individuals (“IP masking”).

3.7.2. New Relic

To perform accessibility and performance monitoring for our servers, we use the "New Relic" web analytics service provided by New Relic Inc., 188 Spear Street, Suite 1200, San Francisco, CA 94105, USA. Using pseudonymized usage data, technical performance data (e.g., response and load times) is measured and analyzed to improve our server performance. Further details and information can be found in the New Relic Privacy Policy at https://newrelic.com/privacy/.

3.7.3. Snowplow

We use the Snowplow open source web analytics service provided by Snowplow Analytics Limited, 32-38 Scrutton Street, London, EC2A 4RQ, United Kingdom. Cookies are used as part of this. The information generated by the cookie about your use of this website, e.g.

• browser type/version
• operating system used
• Referrer URL (the previously visited page)
• hostname of the accessing computer (IP address)
• time of server request
• search queries and filter settings
• clicks on the website

is transmitted to a HomeToGo server in Frankfurt and stored there.

The information is used to evaluate the use of the website, to compile reports on the activity on the website, and to provide other services related to the use of the website and internet usage for the purposes of market research and to customize the design in line with the needs of users.

3.7.4. Adjust

In our app, we use the analytics service of Adjust GmbH, Saarbrücker Str. 37A, 10405 Berlin, Germany. The analytics service is implemented in our app via a development environment (SDK - Software Developer Kit). The information generated by the development environment, e.g.

• hashed (anonymized) IP address
• mobile identifiers such as the Advertising ID for iOS (IDFA) or the Google Advertising ID
• installation and initial opening of an app on your mobile device
• your interaction within an app (e.g., in-app purchases, registration),
• viewed and clicked ads

is collected and used by Adjust GmbH to evaluate the use of the app, to compile performance reports on app activity, and to provide other services related to the use of the app for purposes of market research and customization of the app. Under no circumstances will the collected data be combined with other data that Adjust obtains via other apps.

You can find more information about Adjust's privacy policy here: https://www.adjust.com/privacy-policy/. You can object to tracking by Adjust at any time within the "Opt-out" section of Adjust's Privacy Policy. To do this, you must select the device for which you do not want Adjust to perform tracking and specify your Device Identifier. Behavior tracking from apps that use Adjust will then be immediately removed on your device.

3.7.5. Videobeat

We use the Videobeat analytics software by Videobeat Networks GmbH, Rathausstr. 4, 20095 Hamburg, Germany, for the analysis of television and online marketing activities. Traffic on our website is monitored via a tracking pixel.

Pixels, also known as tracking pixels, are small 1x1-pixel GIF files that can be hidden e.g. in graphics or in e-mails when visiting a website. Pixels do not damage your device and do not contain viruses, Trojans or other malware.

Through the pixel, IP addresses already collected anonymously are stored together with other data (e.g., operating system or device) in a database. Neither we, nor Videobeat can use that data to identify a concrete person . The information in the database is for the purpose of analysis and evaluation for the production of media plans.

Videobeat’s Privacy Policy can be found here: https://www.videobeat.net/us/data-privacy-policy/. You can object to the collection of your data by Videobeat at any time by clicking here: https://pa.videobeat.net/index.php?module=CoreAdminHome&action=optOut&language=en.

3.7.6. Matomo

Additionally, we use the Matomo (formerly Piwik) open source web analytics service provided by InnoCraft Ltd., 150 Willis St, 6011 Wellington, New Zealand (“Matomo”). For this, cookies are used to enable analysis the use of our website. From this data, pseudonymized user profiles can be created and analyzed. The information generated by the cookie, such as your browser and pseudonymized IP address, is processed on our servers. The information generated by the cookie in the pseudonymous user profile is not used to personally identify you and is not combined with your personal data.

More information on data protection when using Matomo can be found here: https://matomo.org/privacy-policy/. There you can object to website tracking via “Opt-out“.

3.8. Targeting

The targeting measures listed below and used by us are implemented on the basis of Article 6 (1) (f) GDPR. Targeting is used to perform targeted advertising. Through the targeting measures we use, we want to make sure that advertisements which are geared to your interests are displayed on your devices.

3.8.1. Double Click

On our website, information used for the optimization of advertisements is collected and evaluated using cookies (see section 3.6.). To do this, we use Google's targeting technologies (Double Click). These technologies enable us to provide you with customized, interest-based advertising. The cookies used provide e.g. information regarding which of our products you are interested in. Based on this information, we can also display services on third-party websites that are specifically oriented towards your interests you have shown through your previous user behavior. The collection and evaluation of your user behavior takes place exclusively in pseudonymized manner and does not enable us to identify you. In particular, the information is not combined with personally identifiable information about you.

The cookie is automatically deleted after 30 days.

You can also set preferences for the display of interest-based advertising through the Google Ads Settings Manager (https://adssettings.google.com/authenticated?hl).

For more information and the privacy policy regarding advertising and Google, please refer to Google’s Privacy Policy and Terms of Service (https://policies.google.com/technologies/ads?hl).

3.8.2. Google AdWords

HomeToGo uses Google's AdWords service, which uses conversion tracking to measure the effectiveness of individual ads, offers and features. For this, a cookie is set as soon as you click on a Google ad. This cookie does not personally identify you, but rather makes it possible to determine whether you return to the page with the specific offer during the 30-day period in which the cookie is valid.

Each AdWords advertiser receives a different cookie. As a result, cookies cannot be tracked via the website of AdWords advertisers. The information obtained using the conversion cookie is used to generate conversion statistics for AdWords advertisers who have opted for conversion tracking. We track the total number of users who have clicked on an ad and were redirected to the website with a conversion-tracking tag.

You can permanently prevent the storage of the Google conversion cookie by setting your browser software accordingly. Google's privacy policy on conversion tracking can be found here: https://services.google.com/sitestats/en.html.

3.8.3. Google Dynamic Remarketing

We use the features of Google Dynamic Remarketing with the cross-device features of Google AdWords and Google DoubleClick.

This feature allows us to link the advertising audiences created with Google Dynamic Remarketing to the cross-device features of Google AdWords and Google DoubleClick. In this way, interest-based, personalized advertising messages that have been customized for you based on your past usage and browsing behavior on a device (e.g., smartphone) may also be displayed on another device you use (e.g., tablet or PC).

If you have given the appropriate consent to Google, Google will link your web and app browsing history with your Google Account for this purpose. That way, the same personalized advertising messages can appear on any device you use to sign in to your Google Account.

To support this feature, Google Analytics collects Google-authenticated IDs of users who are temporarily linked to our Google Analytics data to define and create audiences for cross-device ad promotion.

You can permanently opt out of cross-device remarketing/targeting by turning off personalized advertising in your Google Account. To do so, follow this link: https://adssettings.google.com/authenticated?hl.

For more information, as well as the provisions regarding data privacy, please see the Google Privacy Policy at https://policies.google.com/technologies/ads?hl.

3.8.4. Google AdSense

On our website, we use Google AdSense for displaying advertisements. In this way we can show you advertisements that may be of interest to you. These advertisements can be recognized by the reference "Google Ads". To do this, Google uses web beacons and cookies (see section 3.6.). The information generated by cookies and web beacons about the use of the website (including your IP address) and delivery of advertising formats is transmitted to a Google server in the US and stored there. Google may share this information with third parties.

We have enabled third-party Google AdSense ads. The data may be transferred to third parties (named at https://support.google.com/dfp_sb/answer/94149).

You can prevent Google AdSense from installing cookies by disabling interest-based ads on Google via the link https://adssettings.google.com/authenticated?hl.

For more information, as well as the provisions regarding data privacy, please see the Google Privacy Policy at https://policies.google.com/technologies/ads?hl.

3.8.5. Google AdMob

We use Google AdMob to display ads in the HomeToGo app. Google uses the Apple "Advertising Identifier" (hereafter “Apple Ad-ID”) for advertising control in the app. A pseudonymized user profile is created under the Apple Ad-ID so that the user can be matched to different advertising segments on the Apple advertising platform in order to be able to display interest-based advertising.

The Apple Ad-ID is a pseudonym that prevents personal plain data from being disclosed to Google. The Apple Ad-ID is transmitted to a Google server in the US and stored there.

You can prevent the use of the Apple Ad-ID by clicking on "No Ad-Tracking" under "Privacy/Advertising" in your system settings. Alternatively, you can also click “Reset Ad ID” to generate a new, randomly chosen Apple Ad ID and thus prevent a profile from being generated.

3.8.6. Criteo

Pixel technologies (see section 3.7.5.) from Criteo SA, 32 Rue Blanche, 75009 Paris, France ("Criteo") collect and store data for marketing and optimization purposes. Together with Criteo, we determine the purposes and means of processing and are therefore jointly responsible for processing.

The pixels send your IP address, the Referrer URL of the visited website, the time when the pixel was viewed, the browser used and previously set cookie information to a web server. This data can be used to create usage profiles under a pseudonym.

Criteo's pixel technologies allow us to evaluate our advertising campaigns and advertising content. Using an algorithm, Criteo analyzes surfing behavior and can then display targeted product recommendations as personalized advertising banners on other websites (“publishers”). You can find more information about Criteo’s technology in Criteo’s Privacy Policy (https://www.criteo.com/privacy/).

Using Criteo will load additional pixels from contractual partners with whom Criteo works. An overview of all publishers and networks that load pixels can be found at https://www.criteo.com/privacy/criteo-works-with-the-following-platforms/. The data collected with Criteo technology will not be used to determine the personal identity of the website visitor unless agreed to separately by the data subject. Any use of data other than that described above or transfer to third parties is excluded.

Most browsers accept pixels automatically. You can use the appropriate tools or browser add-ons to prevent the use of pixels on our website (for example, by using the "AdBlock" add-on for the Firefox browser).

You can also object to the pseudonymous analysis of your surfing behavior by us at any time. For instructions on disabling Criteo's service, please visit the following Criteo link: https://www.criteo.com/privacy/.

Please note that if you opt out of displaying personalized ads from Criteo and other affiliates, you will still receive advertisements, however these will be less tailored to your interests/browsing habits.

3.8.7. Bing Ads

We use Bing Universal Event Tracking (UET) from Microsoft Bing Ads. This is a service of Microsoft Corporation, One Microsoft Way, Redmond, WA 98052, USA ("Microsoft"). This allows us to track user activity on our website when users reach our website through advertisements from Bing Ads.

If you reach our website via a Bing Ads advertisement, a cookie will be placed on your computer (see section 3.6.). A Bing UET tag is integrated into our website. This is a code that is used to store data about the use of the website in connection with the cookie. Among others, this includes the time spent on the website, which areas of the website were accessed, and what ads brought users to the website. Information about your identity is not collected.

This information is transmitted to Microsoft servers in the US and stored there for a maximum of 180 days.

More information on Bing Ads’ analytical services can be found on Bing Ads website (https://help.bingads.microsoft.com/#apex/3/en/53056/2). For more information about Microsoft’s privacy practice, please see Microsoft’s Privacy Policy (https://privacy.microsoft.com/en-us/privacystatement).

3.8.8. Outbrain

On our website, we use technology from the service provider Outbrain Inc., 39 West 13^th Street, New York, NY 10011, USA (Outbrain, Outbrain Widgets, Outbrain Pixel). This technology enables us to use pixels (see section 3.7.5.) and cookies (see section 3.6.) to offer further content that may also be of interest to you within our website or on third-party websites ("retargeting"). The recommendations integrated by Outbrain are determined on the basis of your previously read content. The content is technically controlled and delivered by Outbrain automatically.

Display takes place on a pseudonymous basis. When selecting appropriate content, the cookie uses information about the source of the device, the type of browser and your IP address, which is fully anonymized by removing the last octet.

More information about Outbrain's Privacy Policy can be found here: https://www.outbrain.com/legal/privacy#privacy-policy. You may opt-out of Outbrain's use of tracking to display interest-based recommendations via the “Opt out” field within Outbrain's Privacy Policy. Please note that you must separately set the opt-out in each device you use to access our website. After objecting, you will continue to be offered interesting additional content, however this will no longer be based on your previous usage behavior on our websites.

3.8.9. Taboola

Our website uses technologies from Taboola Inc., 28 West 23rd St., New York, NY 10010, USA ("Taboola"). Taboola uses cookies (see section 3.6.) that determine which content you use and which of our pages you visit (conversion tracking). The cookie enables us to create pseudonymous usage profiles by collecting device-related data as well as log data, and enables us to recommend content that matches your personal interests. This permits us to individually customize our offerings for you. These usage profiles cannot be used to establish your identity.

You can find more information about Taboola and the ability to disable the Taboola cookie here: https://www.taboola.com/privacy-policy.

3.8.10. Facebook Custom Audiences

In addition, we also use Facebook Custom Audiences. Facebook Custom Audiences is a Facebook marketing service. It allows us to display personalized and interest-based advertising on Facebook to certain groups of pseudonymized visitors to our website who also use Facebook.

A Facebook Custom Audience pixel is integrated into our website. This is a Java Script code used to store non-personal information about your use of the site. This includes your IP address, the browser you are using, and the source and destination pages. This information is transmitted to Facebook servers in the United States. There, an automatic check is performed to see if you have saved a Facebook cookie. The Facebook cookie automatically determines whether you belong to the relevant target group for us. If you belong to the target group, we will show you relevant ads on Facebook. You will not be personally identified by us or by Facebook as part of this process.

You may object to the use of the Custom Audiences service on the Facebook website (https://www.facebook.com/ads/website_custom_audiences). After logging in to your Facebook account, you will be taken to the settings for Facebook ads.

For more information on privacy on Facebook, see Facebook’s Privacy Policy (https://www.facebook.com/privacy/explanation).

3.8.11. RTB House

On our website, we use technology from RTB House S.A., 61/101 Złota Street, 00-819 Warsaw, Poland. This technology enables us to use pixels (see section 3.7.5.) and cookies (see section 3.6.) to offer further content that may also be of interest to you within our website or on third-party websites ("retargeting"). Cookies are used as part of this process. The recommendations integrated by RTB House are determined on the basis of your previously read content. The content is technically controlled and delivered by RTB House automatically. Display takes place on a pseudonymous basis.

The information generated by the cookie about your use of this website, such as browser type/version, operating system used, Referrer URL (the previously visited page), time of server request is transmitted to RTB House’s server and stored there.

You can find more information on RTB House's privacy policy here: https://www.rtbhouse.com/privacy/. You may object to RTB House's tracking to display interest-based advertising at any time via the opt-out box within RTB House's Privacy Policy. Please note that you must separately set the opt-out cookie in each device you use to access our website. After objecting, you will continue to be offered interesting additional content, however this will no longer be based on your previous usage behavior on our websites.

3.8.12. Airbnb promotional content

Our partner Airbnb Ireland UC ("Airbnb") uses tracking codes (hyperlinks and cookies, see section 3.6.) to collect information when you click on Airbnb promotional content on our website. This information includes

• the hostname of the accessing computer (IP address)
• browser type/version
• operating system used
• type of device used (e.g., smartphone or desktop) and user ID
• location (country, region) and day of the server request.

Airbnb uses the technology to monitor, analyze and report on the performance, operation and effectiveness of Airbnb advertisements on the website. Airbnb uses a third party service provider to deliver and operate this technology on Airbnb’s behalf. Airbnb shares information obtained via this technology with HomeToGo for reporting purposes.

For Airbnb’s contact details, further information about Airbnb's use of the technology and of personal data, as well as information about your rights and choices in this context, see Airbnb's Privacy Policy (https://www.airbnb.co.uk/terms/privacy_policy) and Cookie Policy (https://www.airbnb.co.uk/terms/cookie_policy).

3.8.13.  Intent Media

On our website, we use technologies of Intent Media Inc., 2 Riding House St, London W1W 7FA, United Kingdom. Intent Media uses cookies (see section 3.6.) and web beacons to collect IP addresses, browser type, referrer URL, time of access and number of clicks with the purpose of targeting and placement of advertisements on our website. You can find further information on the technology here: https://intentmedia.com/privacy-policy/.

Information on your use of our website collected via cookie is transmitted to Intent Media servers, stored there and analyzed to personalize advertising on the website and other websites you visit.

You can object to Intent Media’s tracking by displaying interest-based recommendations at any time by clicking this link: http://intentmedia.com/opt-out/.

3.8.14. Clicktripz

On our website, we also use services by Clicktripz, 1112 Ocean Drive, CA 90266 Manhattan Beach, USA. Clicktripz collects and processes user’s travel criteria and shopping behavior through the use of cookies (see section 3.6.) and other means to provide relevant offers from partnering travel websites.

You can find more information in Clicktripz’s privacy policy: http://www.clicktripz.com/privacy_policy.php.

3.8.15. Ad Up

Technology from Ad Up, a service provider of Axel Springer Teaser Ad GmbH, Axel-Springer-Str. 65, 10969 Berlin, Germany, is also integrated on our website. Ad Up uses cookies for conversion tracking, the evaluation of the effectiveness of advertisements and keywords. By collecting anonymized and/or pseudonymous data, Ad Up can display advertisements according to your interests for a certain period of time.

More information can be found in Ad Up’s privacy policy here: https://www.adup-tech.com/en/privacy. You can deactivate Ad Up in your browser by clicking the button “activate opt-out cookie” there.

3.8.16.  Option to object/opt-out

You can prevent the targeting technologies we described by activating the appropriate cookie setting in your browser (see also section 3.6.). In addition, you have the option of deactivating preference-based advertising with the help of the preference manager available here: http://www.youronlinechoices.com/uk/your-ad-choices.

3.9.    Third party websites

HomeToGo cooperates with partners (see in-detail our Terms of Service where our partners are referred to as “Providers” in section 1 (1)). Once you are redirected to a partner’s website, the terms of the respective partner apply.

Neither partners, nor intermediaries of the partner’s offers (affiliate) drop cookies or use other tracking-codes on our website. Cookies or tracking-codes are used after the redirection, upon which HomeToGo has no influence. The following affiliate services are used:

• Performance advertising network by AWIN AG, Eichhornstr. 3, 10785 Berlin, Germany; you can find AWIN’s privacy policy here: https://www.awin.com/gb/legal/privacy-policy-gb.
• Performance Horizon Group Ltd, West One, Forth Banks, Newcastle upon Tyne NE1 3PA, United Kingdom; you can find Performance Horizon’s privacy policy here: https://performancehorizon.com/privacy-policy.
• CJ Affiliate, Commission Junction LLC, 530 East Montecito St., Santa Barbara, CA 93103, USA; you can find CJ’s privacy policy here: https://www.conversantmedia.com/legal/privacy.

4. Google Maps

We use Google Maps API for displaying interactive maps directly on our website and to enable the simplified use of map functionality. Your IP address is transmitted and stored on one of Google’s servers in the US for the usage of Google Maps functionality (see section 3.7.1 regarding the US Privacy Shield). Legal basis is (Article 6 (1) (f) GDPR). 

Please see the Terms of Service for Google Maps here: https://www.google.com/intl/en/help/terms_maps.html. You can find further information on data privacy in Google’s Privacy Policy here: https://policies.google.com/privacy.

5. Contact form

We provide you with a contact form which you can use to ask us questions by entering your name and your email address. The use of the contact form is voluntary, and your data is processed in order to fulfill our contractual service obligations (Article 6 (1) (b) GDPR).

The questions and the information you enter will be transferred to our ticket system. To this end, we make use of the support services of Desk.com, 1 Market Steet, San Francisco, CA 94105, USA. If you do not wish to have your data processed by Desk.com, please contact our customer service directly at info@hometogo.com.hk.

6. Your rights

6.1. Overview

In addition to the right to revoke the consent you have granted to us, you are entitled to the following further rights if the relevant legal requirements apply:

• Right of access to information about your personal data stored with us pursuant to Article 15 GDPR
• Right of rectification of inaccurate personal data and right to have incomplete personal data completed pursuant to Article 16 GDPR
• Right to erasure of your personal data stored by us pursuant to Article 17 GDPR
• Right to restriction of processing of your data pursuant to Article 18 GDPR
• Right to data portability pursuant to Article 20 GDPR

6.2. Right to object

Under the conditions of Article 21 (1) GDPR, data processing can be objected to on grounds relating to the particular situation of the data subject.

The above general right of objection applies to all processing purposes described in this Privacy Policy which are based on Article 6 (1) (f) GDPR. Unlike the special right of objection to data processing for advertising purposes, under the GDPR we are only obliged to implement such a general objection if you give us reasons of overriding importance for this (for example, possible danger to life or health). In addition, you may also contact the supervisory authority responsible for HomeToGo, the Berlin Commissioner for Data Protection and Freedom of Information, Friedrichstr. 219, 10969 Berlin, Germany, Phone: +49 (0) 30 13889-0, Fax: +49 (0) 30 2155050, Email: mailbox@datenschutz-berlin.de.

Version 1.1 – As of 25 May 2018