Mint House Inc.

Privacy Policy

Last updated:  March 8th, 2019

 

Mint House Inc. (“Mint House,” “we,” “our” or “us”) respects your privacy and is committed to protecting it through our compliance with this privacy policy. Mint House offers fully furnished apartments (the “Units”) that combine the comforts of home and the quality of luxury apartments and hotels (the “Property”) on a short-term basis for guests (“Guests”) to stay. The website at www.minthouse.com and any other websites or mobile applications relating to Mint House or the Units (the “Sites”) and the various other related services, features, functions, software, properties, applications, websites and networks (together with the Units and the Sites,  collectively, the “Mint House Services”) are provided and operated, and are being made available to you, the other Guests and the other users of Sites and other Mint House Services (collectively, “Users”). This privacy policy explains our policies and practices regarding the information we collect from and about you. We want to provide you with a level of comfort and confidence in how we collect, use, and safeguard personal and other information we collect and obtain, or that you provide, through the Sites and the other Mint House Services and how you can contact us if you have any questions or concerns.

For the purposes of the EU General Data Protection Regulation 2016/679 (the “GDPR”), Mint House is the data controller. This means that we are responsible for deciding how we use the information that we hold. We are a Delaware corporation registered in the United States with an office at 335 Madison Avenue, Suite 5F2, New York, NY 10017 USA. The GDPR applies to you if you reside in the European Economic Area (an “EEA Resident”).

 

Please note that by making a reservation or renting a Unit or accessing or using the Sites or any other Mint House Service, you are accepting the practices described in this privacy policy. This privacy policy is also incorporated by reference into the Mint House Terms of Service (as modified from time to time, the “Terms”), and the various other policies, agreements and terms and conditions that govern your making a reservation or renting a Unit or your use of Sites or other Mint House Services.

This privacy policy describes the types of information we may collect from you or that you may provide when you make a reservation or rent a Unit or access or use the Sites or any other Mint House Service and our practices for collecting, using, maintaining, protecting and disclosing that information. This policy applies to information we collect or may collect:

  • When you access and use the Sites or other Mint House Services.

  • When you make a reservation for a Unit.

  • When you check in and rent a Unit.

  • When you use one of our booking partners that sell bookings for us (e.g. Airbnb, Expedia, Booking.com, Tripadvisor, Bridgestreet, other online travel agencies) (such booking partners collectively, “Booking Partners”).

  • In e-mail, text and other electronic messages sent through or in use of the Sites or other Mint House Services.

  • When you interact with the other Users.

  • When you send any content through the Sites or any other Mint House Service.

  • Through services provided to us by third-party companies, agents or contractors, including our Booking Partners, Payment Processors and data storage providers.

It does not apply to information collected by:

  • Use offline or through any other means, including on any other website operated by Mint House or any third party; or

  • Any third party, including our Booking Partners and Payment Processors.

Please read this privacy policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your only choice is not to make a reservation or rent a Unit or use the Sites or any other Mint House Service.  By making a reservation or renting any Unit or accessing or using the Sites or any other Mint House Service, you agree to this privacy policy. This privacy policy may change from time to time. Your continued use of any Mint House Service, after we make changes is deemed to be acceptance of those changes, so please check this privacy policy periodically for updates. Nothing in the foregoing paragraph is intended to affect any rights that an EEA Resident might have, or restrictions that might apply, under the GDPR.

Minors under the Age of 18

 

Minors under 18 years of age may not make a reservation for a Unit (although minors under 18 years of age may stay with a guest who is 18 years or older in accordance with the Terms). No one under age 13 may provide any information on or through the Sites or any other Mint House Service. We do not knowingly collect personal data from children under 13. If you are under 13, do not use or provide any information on or through any of the Mint House Services or any of its features on the Sites, and do not use any of the interactive or public comment features of the Sites or any of the other Mint House Services or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received personal data from a child under 13 without verification of parental consent, we will delete that information. If you believe that we might have any information from or about a child under 13, please contact us at info@minthouse.com.

Information We Collect About You and How We Collect It

We collect or may collect several types of information from and about you, other Guests of the Units and other Users, including:

  • Information by which you may be personally identified, such as name, e-mail address, address, phone number and other information from your driver’s license or passport (“personal data”);

  • Information that you provide in making a reservation for a Unit;

  • Information that you provide when you check-in, including information that is collected when we scan your ID (e.g., license, passport, etc.);

  • Information relating to the use of the Unit;

  • Financial and billing information;

  • Information that is about you but individually does not identify you, such as IP address and date and time of visit;

  • Usage details and information, including how you communicate with other Users;

  • Device, internet and mobile information such as the hardware model, operating system version, unique device identifiers, browser type, language, wireless network, and mobile network information (including the mobile phone number);

  • When you report a problem with a Unit, the Sites or any of the other Mint House Services;

  • Records and copies of your correspondence (including e-mail addresses), if you contact us;

  • Details of transactions you carry out through the Sites or any other Mint House Service; and

  • Your search queries on or through the Sites or any other Mint House Service.

We collect this information:

  • Directly from you when you provide it to us.

  • Automatically as you navigate through or use the Sites and other Mint House Services.

  • From third parties, business partners and other third parties that provide us or you with certain services, including our Booking Partners and Payment Processors.

Certain web transactions may also involve you calling us or our calling you. Please be aware that we may monitor and in some cases record such calls for staff training or quality assurance purposes.

You may now or in the future provide pictures, text, data, information and other input or any other content linked, posted or submitted by you or other Users to be published or displayed (hereinafter, “posted”) on or through the Sites or any of our social networking pages (e.g., Facebook, Twitter, Instagram), or transmitted to third parties or other Users of or any of the other Mint House Services (collectively, “User Content”). Your User Content is posted on and transmitted to others at your own risk.  We cannot control the actions of other Users, or our social networking pages, with whom your User Content is shared. Therefore, we cannot and do not guarantee that your User Content will not be viewed, downloaded or shared by unauthorized persons.

Use of Cookies and Other Tracking Technologies.

 

The technologies we use for automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of the Sites or other Mint House Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to the Sites.

  • Flash Cookies. Certain features of the Sites may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on the Sites. Flash cookies are not managed by the same browser settings as are used for browser cookies.

Do Not Track Policy

Your web browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. We do not honor any web browser “Do Not Track” signals or other mechanisms that provide you with the ability to exercise choice regarding the collection of personally identifiable information about your online activities over time and across third-party websites or online services. At present, no universally accepted standards exist on how companies should respond to do-not-track signals. In the event a final universally accepted standard is established, we will assess and provide an appropriate response to these signals.

Third-Party Responsibilities and Services

We use or partner with other third-party companies, agents or contractors, including our Booking Partners, Payment Processors and data storage providers, for various purposes in connection with our business and operations (“Service Providers”). Such purposes include making reservations, texting, ID scanning, CRM, property management, billing and payments, credit card gateway, cloud hosting, relationship building, the marketing and growth of our business and the performance of services on our behalf, such as gathering and analyzing information and the provision of services to you. In the course of performing these responsibilities and providing such services, these other companies may have access to your information, including your personal data. We may also share information, including your personal data and other information, with these Service Providers in order to enable them to perform these responsibilities and to provide these services.  Many Service Providers have adopted their own privacy policies, which are not subject to control by Mint House. You should always review the policies of these Service Providers to make sure that you are comfortable with the ways in which they collect, use, maintain, protect and disclose your information. We do not specifically list our current Service Providers because they change from time to time. If you would like the names of our Service Providers, please email us at info@minhouse.com

The Service Providers may also transmit cookies to your computer or device, when you click on ads that appear on or through the Service. Also, if you click on a link to a third-party website from the Sites, including, links to news and articles about us and the Properties, such third party may also transmit cookies to you and we do not have any control over that. Please be aware that cookies placed by third parties may continue to track your activities online even after you are no longer using any of our Services, and those third parties may not honor “Do Not Track” requests you have set using your web browser.

Reservation System - Guesty

 

We use Guesty to store all of the data we receive from Guests regarding reservations of Units. We do this to provide a reliable and secure booking process while concentrating on our real business of hospitality. Any personal information you share when making a reservation will be shared with Guesty in order to process it. More information about Guesty and its privacy policy can be found here: https://www.guesty.com/privacy-policy/.

 

Facebook Pixel

 

We use Facebook Pixel to track conversions and direct relevant advertising to our Users. Facebook Pixel allows us to measure the effectiveness of our advertising by understanding the actions Users take on the Sites and other Mint House Services. You can opt out by following the instructions here: http://optout.aboutads.info. More information about Facebook and its privacy policy can be found here: https://www.facebook.com/about/privacyshield.

Use of Remarketing with Google Ads, Google Analytics and other Remarking and Analytic Services

 

We use or may in the future use a variety of remarketing and analytic services including:

 

Google Ads

The Sites use Google Ads to advertise in search results to previous visitors to our Sites or to individuals who search for specific key terms or phrases. It could mean that we advertise to previous visitors who have not completed a task on our Sites; for example, using the contact form to make an inquiry. This could be in the form of an advertisement in the Google search results or on a site in the Google Display Network Third-party vendors, including Google, use cookies to serve ads based on someone’s past visits to the Sites. Of course, any data collected will be used in accordance with this privacy policy, as well as Google’s privacy policy.

Google Analytics and Google Search Console

We use “Google Analytics” and “Google Search Console” to collect information about use of the Sites. Google Analytics collects information such as how often users visit the Sites, what pages they visit when they do so, and what other sites they used prior to coming to the Sites. We use the information we get from Google Analytics to improve the Sites and other Mint House Services, and their related features, functionality and performance. Google Analytics collects only the IP address assigned to you on the date you visit our Sites, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit the Sites, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to our Sites is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You can prevent Google Analytics from recognizing you on return visits to the Sites by disabling cookies on your browser. You can set preferences for how Google advertises to you using the Google Ad Preferences page, and if you want to, you can opt out of interest-based advertising entirely by cookie  settings or permanently using a browser plugin. Google has additional information available about its Remarketing Privacy Guidelines, Policies, and Restrictions on its website.

Google Tag Manager

The Sites use Google Tag Manager. Google Tag Manager is a solution that allows marketed website tags to be managed using an interface. The Tag Manager tool itself (which implements the tags) is a cookie-less domain and does not register personal data. The tool causes other tags to be activated which may, for their part, register data under certain circumstances. Google Tag Manager does not access this information. If recording has been deactivated on domain or cookie level, this setting will remain in place for all tracking tags implemented with Google Tag Manager.

How We Use Your Information

We will only use information that we collect about you or that you provide to us, including any personal data for the purposes described in this privacy policy and when applicable law allows us to do so. We will generally use your information based on the following legal grounds: 

  • Where the use of your information is necessary for the performance of a contract that we are about to enter into or have entered into with you;

  • Where the use is necessary for the purposes of our legitimate interests (or those of a third party);

  • Where we need to comply with a legal or regulatory obligation; or

  • Where you have given your consent (which can be withdrawn at any time).

We use information that we collect about you or that you provide to us for the following purposes: 

  • To provide you the Units, the Sites and other Mint House Services and the other services and products that you request from us.

  • To provide you with notices about your reservation.

  • To manage Guest services and requests while staying in a Unit.

  • To provide the Sites and their content to you.

  • To provide technical and other support to you.

  • To solicit reviews.

  • To generate leads.

  • To send you promotional communications, such as providing you with information about the Units, services, features, surveys, newsletters, offers and events and providing other news or information about us, our customers and our select partners; provided that you have given your consent if required by applicable law.

  • To enable Service Providers to perform certain responsibilities and provide certain services in connection with our business and operations.

  • To fulfill any other purpose for which you provide it.

  • To carry out our obligations and enforce our rights arising from the Terms and any other agreements entered into between you and us, including for billing and collection.

  • To notify you about changes to the Units, the Sites and the other Mint House Services.

  • To allow you to participate in interactive features on or through the Sites or any other Mint House Service.

  • To enhance the safety and security of all of the Sites and the other Mint House Services.

  • To verify your identity and prevent fraud or other unauthorized or illegal activity.

  • To enable marketing, remarketing and targeted advertising and similar services from us or Service Providers, including direct and indirect marketing and on-line behavioral advertising regarding our own and third-party products and services that we believe may be of interest to you, including advertisement on third party websites; provided that you have given your consent if required by applicable law.

  • To perform targeted and other advertising on third party websites.

  • In any other way we may describe when you provide the information.

  • For any other purpose with your consent.

We may also use any information that has been anonymized or in an aggregated form that does not directly identify you for any purpose (including to create and distribute marketing materials such as testimonials, case studies, white papers, savings calculators, etc.) to the extent not prohibited under any applicable law or regulation.  

Some of the information that we collect automatically is statistical data and does not include personal data, but we may maintain it or associate it with personal data we collect in other ways or receive from third parties or you provide to us. It helps us to improve the Units, the Sites and other Mint House Services, and to deliver a better and more personalized service, including enabling us to:

  • Estimate our audience size and better understand usage patterns.

  • Store information about your preferences, enabling us to customize the Sites according to your individual interests.

  • Speed up your searches.

  • Recognize you when you return to the Sites.

Storage and Transfer of Your Information

We may store any information that we collect (personal or otherwise) ourselves or in databases owned and maintained by us, our affiliates, agents or Service Providers. If you access or use the Sites or any of the other Mint House Services outside of the United States, information that we collect about you may be transferred to servers inside the United States and maintained indefinitely, which may involve the transfer of information out of countries located in the European Economic Area and other parts of the world unless otherwise prohibited by applicable law or agreed by Mint House and you. By allowing Mint House to collect information about you, you consent to such transfer and processing of such information without restriction. We may also store some information locally on your computer or other devices. For example, we may store information as local cache so that you can open the Site and view content faster.

Although users from all over the world may access the Sites and the other Mint House Services, keep in mind that no matter where you live or where you happen to use our services, you consent to us processing and transferring information in and to the United States and other countries whose data-protection and privacy laws may offer fewer protections than those in your home country.

Disclosure of Your Information

We may disclose anonymized or aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal data that we collect or you provide as described in this privacy policy:   

  • To our subsidiaries and affiliates.

  • To the owners and managers of the Property.

  • To Service Providers, contractors and other third parties we use to support our business, including credit card payment processors and marketing support.

  • To a potential or actual buyer. assignee or other successor (including its related advisors and agents) in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of the Mint House’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal data held by Mint House about you and other users of the Sites is among the assets that may be or are actually transferred.

  • To fulfill the purpose for which you provide it. 

  • For any other purpose disclosed by us when you provide the information.

  • With your consent.

We may also disclose your personal data:

  • To comply with any court order, law or legal process, including to respond to any government or regulatory request.

  • To enforce or apply the Terms and any other agreements between you and us, including for billing and collection purposes.   

  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Mint House, the Property, our Guests or others. 

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal data you provide to us. We have created mechanisms to provide you with the following control over your information:

  • Promotional Offers from Mint House. If you do not wish to have your e-mail address/contact information used by Mint House to promote our own or third parties’ products or services, you can opt out through the unsubscribe mechanism at the bottom of the applicable email. This opt out does not apply to information provided to Mint House as a result of a service or product purchase, product service experience or other transactions. 

 

  • We do not control third parties' collection or use of your information to serve interest-based advertising. You may be able to opt out of receiving personalized advertisements from companies who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance's Self-Regulatory Principles for Online Behavioral Advertising. For more information about this practice and to understand your options, please visit: http://www.aboutads.info and http://www.networkadvertising.org/choices/. You may also use TRUSTe's Preference Manager at http://preferences-mgr.truste.com

Accessing and Correcting Your Information

 

You may change, correct or delete any personal data that you have provided to us by contacting us by e-mail at info@minthouse.com. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Content from any of the Mint House Services (including any User Content stored in the cloud), copies of your User Content may remain viewable in cached and archived pages, or might have been copied or stored by other Users of the Sites or other Mint House Services. Proper access and use of information provided on or through any of the Mint House Services, including User Content, are governed by the Terms.

Your California Privacy Rights

California Civil Code Section §1798.83 permits Users that are California residents to request certain information regarding our disclosure of personal data to third parties for their direct marketing purposes. To make such a request, please send an e-mail to us at info@minthouse.com or write to us at: Mint House Inc., 335 Madison Avenue, Suite 5F2, New York, NY 10017 USA.

European Privacy Rights for EEA Residents.

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your personal data) if we intend to use your personal data for such purposes or if we intend to disclose your personal data to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your personal data. You can also exercise the right by contacting us directly.

In certain circumstances, you have the right to: (a) request access to any personal data we hold about you and related data, (b) obtain without undue delay the rectification of any inaccurate personal data, (c) request that your personal data be deleted provided that the personal data is not required by us for (i) compliance with a legal obligation under European or Member State law or other applicable law or (ii) the establishment, exercise or defense of a legal claim, (d) prevent or restrict processing of your personal data, except to the extent processing is required (i) to comply with a legal obligation under European or Member State law or applicable law or (ii) for the establishment, exercise or defense of legal claims; and (e) request transfer of your personal data directly to a third party where this is technically feasible.

If you are an EEA Resident in France, you also have the right to set guidelines for the retention and communication of your personal data after your death.

If you reside in a jurisdiction other than the European Economic Area, you may also have similar rights to the above. Please contact us at info@minthouse.com if you would like to exercise one of these rights, and we will comply with any request to the extent required under applicable law.

In addition, where you believe that we have not complied with its obligation under this Privacy Policy or European law, you have the right to make a complaint to an EU Data Protection Authority, such as the UK Information Commissioner’s Office.

You can exercise any of these rights by contacting us at info@minthouse.com or write to us at: Mint House Inc., 335 Madison Avenue, Suite 5F2, New York, NY 10017 USA.

How Long We Store Your Personal Data

We will only retain your personal data, in a form which permits us to identify you, for as long as necessary to fulfil the purposes we collected it for. We will retain and use your personal data as necessary to satisfy any legal, accounting or reporting requirements, to resolve disputes or to enforce our agreements and rights. After that, we will either securely delete or anonymize your personal data so that it cannot be linked back to you.

Data Security

 

We understand that the security of your personal data is important. We provide reasonable administrative, technical, and physical security controls to protect your personal data.  However, despite our efforts, no security controls are 100% effective and Mint House cannot ensure or warrant the security of your personal data. Any transmission of personal data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site. 

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to and use of the Sites or any other Mint House Service, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Sites or other Mint House Services. The information you share in public areas may be viewed by any other user of the Sites and the other Mint House Services.

 

Changes to Our Privacy Policy

 

We may post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the home pages of the Sites for at least 30 days and/or notify you of such changes by email. If we make material changes to how we treat our Users' personal data that are materially less protective than provided in this policy, we will use reasonable efforts to notify you by e-mail using the e-mail address specified in your account and/or through a notice on the home pages of the Sites and to attempt to get your consent to the changes. The date the privacy policy was last updated is identified above. You are responsible for ensuring that we have an up-to-date, active and deliverable e-mail address for you, and for periodically visiting the Sites and this privacy policy to check for any changes.  Like our Terms, of which this privacy policy is a part, your use, or continued use after our efforts to contact you, of the Sites or any of the other Mint House Services, means that you agree to be bound by such changes.

Survival

 

The policies indicated in this privacy policy will remain effective, even if the Terms and the other agreements between you and us are terminated and you are no longer renting any Units or using the Sites or any of the other Mint House Services.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices or if you need to reach us for any other reason, you may contact us by e-mail at info@minthouse.com or by mail at Mint House Inc., 335 Madison Avenue, Suite 5F2, New York, NY 10017 USA.

 

© Copyright Mint House Inc. 2019