Privacy policy

Introduction

What's the privacy policy for ?

At Luckey Homes, protecting your personal data is a priority!

The purpose of this privacy policy is to provide you with information about the way we process your personal data.

You can rest assured that when collecting and managing your data, we are fully compliant with the so-called "Informatique et Libertés" law of 1978 (the French data protection act) and now with the (new and much-discussed) European data protection regulation of 27 April 2016 (hereafter referred to as the " GDPR »).

What is personal data ?

During your use of our websites (luckey.app, luckey.fr, luckey.ca, luckeyhomes.uk, luckeyhomes.ch, luckey.family) or of our mobile application (hereafter referred together as the " Platform"), we may ask you to supply us with personal data concerning you in order to use our services (hereafter referred to as the " Services »).

The term " personal data " refers to all data making it possible to identify you as an individual.

Which personal data is collected by Luckey Homes?

During our activities and via the services we offer, we may gather some information concerning our customers and partners:

  • Website visitor (A) : IP address, visited pages logs
  • Lead sign up (B): (A) + last name, first name, phone number, email address, information concerning your accommodation (address, surface, photos, number of bedrooms, number of bathrooms)
  • Host sign up (C: (B) + age, residential address, profile picture, identification video, proof of identity, bank account details, detailed information about the rental, data concerning your transactions (bookings, payments, invoices…)
  • Service provider sign up (D): (A) + last name, first name, phone number, email address, resume, cover letter, proof of identity, bank account details
  • Guest making a booking on a platform (ex : Airbnb): last name, first name, phone number, email address, language, country, information about the booking + (A) if they connect on our dedicated guest website
  • Employee: (D) + any information needed for legal reason

Who is the data controller ?

Us !

LUCKEY SAS , a simplified joint stock company, registered in the Trades & Companies Register of Paris under the no. 812 226 926, having its registered office at 10 rue de Penthièvre – 75008 Paris

Email : [email protected]
Téléphone : (+33) 6 44 60 20 21

1. The use of your personal data

On which bases is your data collected and used ?

Contract

Legitimate Interest

Legal Obligation

Consent

This collection is necessary to implement the contract concluded when you use our Services on our Platform

When you supply personal data voluntarily, we collect it in order to better able to meet your requests for information on our Platform.

When the processing of your data is necessary to comply with the legal obligations to which we are subject

This involves the collection and storage of your personal for information and prospection material


For which end purpose(s) is your data collected and used?

Creating a database of users, registered members and prospects.


Managing your access to our Services accessible via the Platform and their use.

The preparation of business statistics and those concerning visits to our Platform.


Personalising replies to your requests for information.


Managing people's opinions concerning the Platform’s Services or content.

Compliance with our legal and regulatory obligationss


Measuring the number of visits to the Platform, the number of page views and our users’ activities.


Sending information or prospection material


NB: You may always refuse to supply us with your data and we will then inform you of any possible consequences this refusal may have when the provision of such data is mandatory.

2. Recipients of the collected data

The following will have access to your personal data :

  1. Our team,
  2. The services handling inspection activities (including the auditors of corporate accounts),
  3. Our subcontractors, and in particular :
    • Mango Pay, or Stripe for our payment services,
    • Linode and Amazon web services for attached files hosting,
    • Intercom, Twilio and Front for interaction with our users and visitors (chat, telephone and e-mail),
    • Heroku for data hosting.
  4. Partners with whom we may work for the performance of our activities (city managers, welcomers, cleaning services).

Not forgetting the following: public authorities, legal officers (bailiffs, notaries, etc.), ministerial officers and debt collection organisations.

3. Personal data retention period

The data is stored for the whole length of your registration for our Services and for a period of :

  • Three years as from your unsubscription date concerning the use of the data for prospection purposes. At the end of this three (3) year period, we may contact you again to find out if you wish to continue receiving commercial communications from us.
  • A minimum of three years as from the date on which you exercise your right of opposition concerning information making it possible to exercise your rights.
  • Five years as from your unsubscription date concerning compliance with legal and regulatory obligations and in order to make it possible to establish proof of a right or a contract.
  • Thirteen months concerning the cookies mentioned in the article below.

4. Security

No worries here! We (and our subcontractors) have taken all necessary precautions in addition to the appropriate organisational and technical measures to protect the security, integrity and privacy of your personal data.

Among others:

  • We have implemented an incident response plan
  • We have advanced build processes that allow us to deploy code several times a day
  • Our backoffice is only accessible to employees with two factor authentification
  • All data sent from/to Luckey is encrypted using strong TLS encryption
  • We have application-level log and server-level logs for all activities
  • We have some integration testing to ensure privacy controls work as expected

5. Hosting

Your data is stored for the whole duration of its processing, on servers located in European Union.

It may also be hosted on the servers of the companies Front, Intercom, Twilio, and Stripe located in the United States.

These are covered by the "Privacy Shield", which has been judged to offer an adequate level of protection in a decision by the European Commission of 12 July 2016 (please see the adequacy decision ). or further information concerning the protection offered by the "Privacy Shield", please visit its website internet .

6. Cookies

Cookies are text files, often encrypted, which are stored on your smartphone. They are created when your smartphone loads an application or website: the application or the website sends information to your smartphone or your browser, which then creates a text file. Whenever you return to the same application or website, your smartphone or browser accesses this file and sends it to the application/website concerned.

There are different types of cookies, which don't all have the same end purpose :

  • Technical cookies are used during your browsing, to facilitate it and to implement certain functions. As an example, a typical cookie can be used to remember the information you entered in a form or your language or layout preferences for an application, when such options are available.

We use technical cookies (including in particular Raygun and Sentry).

  • Social network cookies may be created by social network platforms to enable website designers to share their content on the said platforms. Among other things, these cookies may be used by the social network platforms to track users’ browsing behaviour on the sites concerned, whether or not they use these cookies.

We use social network cookies (Facebook, Linkedin).

We also invite you to consult the privacy protection policies of the social network platforms which create these cookies, to familiarise yourself with the end purposes for which the browsing information they gather via these cookies may be used, and for instructions on how to exercise your rights vis-a-vis these platforms.

  • Advertising cookies may be created not only by the website which you are browsing but also other websites displaying advertising, announcements, widgets or other content on the page displayed. Among other things, these cookies may be used to carry out targeted advertising, i.e. advertising based on your browsing information.

We use advertising cookies (Facebook, Google, Intercom, Outbrain).

  • We also use Google Analytics and Mixpanel, which are statistical audience analysis tools generating a cookie making it possible to measure the number of visits to our Platform, the number of page views and the users’ activities. Your IP address is also collected in order to determine from which town you are connecting.

We would like to remind you that you may oppose the placing of cookies on your device by configuring your browser or smartphone to this effect.

7. Your rights

What are your rights concerning your data ?

The right to information

It's for this reason that we have drafted this privacy policy

Right of access

You have the right to access all of your personal data at any time


Right of rectification

You have the right to rectify your personal data at any time if this is inaccurate, incomplete or obsolete

The right to limitation

You have the right to demand that the processing of your personal data be restricted in certain cases described in art.18 of the GDPR

The right to data portability

You have the right to receive your personal data in a readable format and to demand its transfer to the recipient of your choice

The right to be forgotten

You have the right to demand that your personal data be deleted and to prohibit any future collection of it

The right to complain

to an authorised regulatory authority (in France, the CNIL), if you consider that the processing of your personal data violates the applicable texts

The right to opposition

You have the right to oppose the processing of your personal data. However, please note that we may continue to process it despite this opposition, on legitimate grounds or to defend rights in court.

Regarding prospection, you may oppose this at any time via the unsubscribe link located at the bottom of each of our prospection e-mails.


The right to leave instructions for after your death

concerning the storage, deletion and communication of your personal data, designating the person responsible for implementing these if necessary. You may send them to a digital trusted third party certified by the CNIL (French data protection authority) in the case of general instructions, or to the contact details below for your specific instructions. You can modify or revoke your instructions at any time.


You may exercise the above-mentioned rights by writing to us at [email protected]

Or the following address for those who prefer to contact us by post : 1 bis Cité du Paradis, 75010 Paris

When contacting us, please supply a copy of a signed identity document.

8. Applicability date

This privacy policy takes effect on 1 January 2018.

9. Modifications

We reserve the right to partially or wholly modify this privacy policy at any time at our sole discretion.

These modifications will take effect as from the publication date of the new privacy policy. Your use of the Platform once these modifications have taken effect constitutes your acknowledgement and acceptance of the new privacy policy. Failing this, if this new privacy policy is unacceptable to you, you must no longer access our Platform.

10. Credits

Credits for the pictograms: designed by Gregor Cresnar, Thomas Soto, Iyikon, Bezier Master, Alina Oleynik, Jaro Sigrist, Three Six Five, Rflor, Rama, AomAm, Por Suppasit, and Pedro Santos from Noun Project.

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Luckey and Airbnb
Since its purchase in December 2018, Luckey has become an Airbnb wholly-owned subsidiary.

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