Last updated: June 17, 2019

Privacy Policy

Content

Preamble

This privacy statement is valid for all the websites hosted by tell Charlie.

In the following, we provide information about the collection of personally identifiable information while using tell Charlie and its' products (including but not limited to the tell Charlie website, messenger web-platform etc.). Personally identifiable information is all data that relates to you personally, such as name, address, e-mail addresses, or user behavior. The protection of your personally identifiable information is very important to us. If you have any questions or would like more information about tell Charlie's data protection, please contact info@tellcharlie.com.

Continuous technological development, changes in our services or the legal situation, and other reasons may require adjustments to our data protection notice. We therefore reserve the right to change this privacy statement at any time and ask that you regularly keep yourself informed of the current state.

1. Party responsible for data controlling

The responsible party, according to Article 4 (7) of the EU General Data Protection Regulation (GDPR), is tell Charlie B.V., Leidseplein 1-3, 1017PR Amsterdam, The Netherlands, E-mail: info@tellcharlie.com.

2. Data protection officer – Point of contact

You can reach our data protection officer at info@tellcharlie.com or our mailing address by adding 'Datenschutz / Data Privacy'.

3. Your rights

You have the following rights with respect to the personally identifiable information concerning you:

3.1. General rights

You have the right to information, correction, deletion, limitation of processing, opposition to processing, and data portability. If processing is based on your consent, you have the right to revoke it with effect for the future.

3.2. Rights in the processing of data based on legitimate interests

According to Article 21 (1) of the GDPR, you have the right to file an objection at any time for reasons arising out of your particular situation against the processing of personally identifiable information relating to you, pursuant to Article 6 (1) of the GDPR (data processing in the public interest) or Article 6 par. 1 f GDPR (data processing for the protection of a legitimate interest); this also applies to a profiling based on this provision. In the event of your objection, we will no longer process your personally identifiable information unless we can establish compelling and legitimate grounds for processing that outweigh your interests, rights and freedoms, or if the processing aids the enforcing, exercising or defending of legal claims.

3.3. Rights in direct advertising

If we process your personally identifiable information for the purpose of direct advertising, you have the right according to Article 21 par. 2 GDPR to object at any time to the processing of personally identifiable information relating to you for the purpose of such advertising; this also applies to profiling, where appropriate, insofar as it is associated with such direct advertising.

In the event of your objection to processing for the purpose of direct advertising, we will no longer process your personally identifiable information for these purposes.

3.4. Right to complain to a supervisory authority

You also have the right to complain to a relevant data protection supervisory authority about our processing of your personally identifiable information.

4. The collection of personally identifiable information when visiting our website

If you are only using the website for informational purposes, i.e., if you do not enroll or otherwise provide us with information, we will only collect the personally identifiable information that your browser transmits to our server. If you wish to view our website, we collect the following data that is technically necessary for us to display our website and ensure its stability and security. Only in the case of suspected misuse in connection with bookings would we use this link information to facilitate the identification of the person responsible. The legal basis for this is Article 6 (1) (f) GDPR:

  • IP address, date and time of the inquiry, time difference to Greenwich Mean Time (GMT), content of the request (concrete page), access status/HTTP status code, amount of data transferred in each case, website that receives the request, browser, operating system and its interface, language, and browser software version.

5. Contact by e-mail or contact form

When you contact us by e-mail or through a contact form, we will store the data you provide (your e-mail address, possibly your name and telephone number) so we can answer your questions. Insofar as we use our contact form to request entries that are not required for contacting you, we have always marked these as optional. This information serves to substantiate your inquiry and improve the handling of your request. A statement of this information is expressly provided on a voluntary basis and with your consent, art. 6 par. 1a GDPR. As far as this concerns information about communication channels (such as your e-mail address or telephone number), you also agree that we may also, where appropriate, contact you via this communication channel to answer your request. You may of course revoke this consent for the future at any time.

We delete the data that arises in this context after saving is no longer required, or limit processing if there are statutory retention requirements.

6. Newsletter

6.1 General information

With your consent under Art. 6 par. 1 a GDPR, you can opt in to our newsletter, which will inform you about our current deals.

To sign up for our newsletter, we use the 'double opt-in' method. This means that after you have signed up, we will send you an e-mail to the e-mail address specified, in which we ask you to confirm that you wish to receive the newsletter.

The only requirement for sending the newsletter is your email address. The specification of additional, separately marked data is voluntary and will be used to address you personally. After your confirmation, we will save your email address for the purpose of sending you the newsletter. The legal basis is art. 6 par. 1 a GDPR.

You may revoke your consent to the sending of the newsletter at any time and opt out of the newsletter. You can declare the revocation by clicking the link provided in each newsletter e-mail or by contacting the aforementioned data protection officer.

6.2. Newsletter Tracking

Please note that we evaluate your user behavior when sending the newsletter. For this evaluation, the emails sent include 'web beacons' or tracking pixels, which are stored on our website. For the evaluations, we link the data mentioned and the web beacons with your e-mail address and an individual ID.

With the data obtained in this way, we generate a user profile to tailor the newsletter to your individual interests. In doing so, we record when you read our newsletters, which links you click on in them and deduce your personal interests. We link this data with actions you have taken on our website.

You can object to this tracking at any time by clicking on the separate link provided in each e-mail. The information will be saved as long as you have opted in to the newsletter. After you log out, we save the data purely statistically and anonymously.

Also, such tracking is not possible if you've deactivated image viewing by default in your email application. In this case, the newsletter will not be displayed in full and you won't be able to use all the features. If you display images manually, the above tracking will take place.

7. Services for accommodation guests

tell Charlie offers the opportunity for accommodation guests to play an active role in improving the guest experience in accommodation providers worldwide and the performance of accommodation providers in general.

We have received personal information on you by the accommodation you chose to stay with or trip provider. We act as a data controller for the partners we work with.

In other cases, we might have received personal information on you by the accommodation provider you chose to stay with. We act as a data controller for the accommodation provider we work with.

If you decide to be an active participant in our services, we will use your data to contact you on behalf of the accommodation provider before, during and after your stay for the purpose of conducting surveys and gathering information regarding your stay.

You can choose which personal information you disclose to us. If you instruct us to, we will disclose the information you provide us with to the accommodation provider you are staying at. The accommodation provider will be enabled to improve your stay by reacting to your feedback.

In any case, we will use and permanently keep the feedback you give us in an anonymized manner, where user feedback is evaluated statistically. We will make sure that no personal data is contained in this aggregated data and use this aggregated and anonymized data for our own marketing purposes and/or may share it with trivago N.V. and/or the accommodation provider in question.

We will save your information until you permanently delete your access or unsubscribe from our messages. We will still save the data that you provided on a voluntary basis for the time of your use of our services, if you do not delete this in advance. You can manage and modify all information in your protected user account. The legal basis is article 6, par. 1 a, b, and f of the GDPR.

7.1 Services for accommodation guests – submitting guest reviews

While using tell Charlie's services, guests may be invited to submit a review on their experience during and after their trip. Guests are asked for their accommodation information, dates travelled, and a name under which the review is shown (can also be made anonymous or under an alias). By submitting a review, guests agree that their review can be displayed on relevant accommodation provider's webpages, tell Charlie and its' parent corporation (and subsidiaries) webpages, mobile pages, social media accounts, and on any other platform related to tell Charlie. Guest reviews are to be solely used to inform other guests about the quality of service of accommodation providers.

Please note that guest reviews are subject to our Reviews Code of Conduct attached above. tell Charlie reserves the right to adjust, refuse, or remove reviews at our sole discretion insofar a review violates our reviews code of conduct.

8. Services for accommodation providers

Accommodation providers can make use of our services by enrolling with us and creating a user account. We collect and save the following data for enrollment:

  • e-mail
  • password
  • customer name
  • property name
  • phone
  • address of property
  • VAT number (if applicable)
  • payment information (if appplicable)

The specification of the aforementioned data is compulsory; all other information you can provide voluntarily by using our portal.

After enrollment, you will receive personal, password-protected access and can view and manage the data you have stored. The data collected will be used solely for implementing the contractual relationship between us and the respective accommodation provider.

If you decide to be an active participant in the tell Charlie product and service offering, we will ask you for personal data of your accommodation guests so we can get in touch with them. tell Charlie ensures that none of your personally identifiable information is visible to any external parties (excluding trivago N.V.). tell Charlie does not publish or forward any personally identifiable information without receiving your express consent to do so. We will act as a data processor on your behalf and offer a corresponding contract you will be provided with by us.

We will save this information until you request us to permanently delete your access. We will still save the data that you provided on a voluntary basis for the time of your use of our service, if you do not delete this in advance. You can manage and modify all information in your protected user account. The legal basis is article 6, par. 1 a, b, and f of the GDPR.

9. Use of cookies

Cookies will be stored on your device during the use of our website. Cookies are small text files that are stored on your hard drive assigned to the browser you use, and through which the place where the cookie is set accrues certain information. Cookies cannot run any programs or transmit any viruses to your device. They serve to make the website more user-friendly and efficient overall. We also use cookies to be able to identify you in subsequent visits.

This website uses the following types of cookies, whose extent and function are explained in the following:

9.1. Transient cookies

These cookies are automatically deleted when you close your browser. This includes session cookies in particular. These save a 'session ID' with which different requests from your browser can be assigned to the joint session. This allows your device to be recognized again when you return to our website. Session cookies are deleted when you log out or close your browser.

9.2. Persistent cookies

These cookies are automatically deleted after a set duration that can vary depending on the cookie. You can delete cookies in your browser security settings at any time.

9.3. Flash cookies

Flash cookies used are not collected through your browser, but through your Flash plug-in. In addition, we use HTML5 storage objects that are stored on your terminal. These objects save the necessary data independent of the browser you use and have no automatic expiration date. If you do not want Flash cookies processed, you must install a suitable add-on, such as 'Better Privacy' for Mozilla Firefox or Cookie AutoDelete for Google Chrome. You can prevent the use of HTML5 storage objects by setting your browser to private mode. We also recommend that you manually delete your cookies and browser history on a regular basis.

9.4. Preventing cookies

You can configure your browser and App settings as you wish and, for example, decline to accept third-party or all cookies. Please note that you may not be able to use all of the website's functions in this case.

9.5. Legal bases and storage period

The legal bases for possible processing of personally identifiable information and its storage period vary and are described in the following sections.

10. Analysis

For the purposes of analyzing and optimizing our websites, we use different services that are described in the following. This allows us to analyze, for example, how many users visit our site, which information is requested the most, and how users find the website. The data that we collect includes the websites from which a person in question arrives at a website ('referrer'), which subpages on the website are accessed and how often, and the length of time for which a subpage is viewed. This helps us to develop and improve our website to be more user-friendly. The data collected does not serve to personally identify individual users. Anonymous or highly pseudonymous data will be collected. The legal basis for this is article 6, par. 1 f of the GDPR.

Google Analytics

This website uses Google Analytics, a web analysis service of Google LLC (1600 Amphitheatre Parkway Mountain View, CA 94043, USA). This use covers the Universal Analytics operating mode. This makes it possible to assign data, sessions, and interactions across multiple devices to a pseudonymous user ID and thus analyze a user's activities across devices.

Google Analytics uses cookies that allow your use of the website to be analyzed. The information generated by the cookie through your use of this website is generally transmitted to a Google server in the USA and stored there. If IP anonymization is activated on this website, however, your IP address will be truncated in advance within the member states of the European Union or other contracting states party to the Agreement on the European Economic Area. Only in exceptional circumstances will the full IP address be transmitted to a Google server in the USA and truncated there. The IP address transmitted from your browser in the context of Google Analytics will not be conflated with other Google data. Google will use this information in this website operator's order to evaluate your use of the website so that reports about website activity can be compiled and other services connected to website and internet use can be rendered for the website operator. Our legitimate interest in data processing is also for these purposes. The legal basis for the use of Google Analytics is article 6, par. 1 f of the GDPR. The data sent by us and connected to cookies, user information (such as user ID), and promotional IDs are deleted after 14 months after the last use of our services. Data whose storage period has expired is automatically deleted once a month. More information on the terms and conditions of use and data protection can be found at Analytics and Policies

You can prevent cookies from being stored through the relevant setting in your browser software; however, please note that if you do so, not all functions of the website may be able to be used to their full extent. You can also prevent the data generated by the cookie and related to your use of the website (including your IP address) from being collected and processed by Google by downloading and installing this. Opt-out cookies prevent the future collection of your data when visiting this website. To prevent Universal Analytics collection across various devices, you must perform the opt-out on all systems in use. Set the opt-out cookie by clicking here: Deactivate Google Analytics

Hotjar

Data is collected and stored for optimization purposes on this service using technologies from Hotjar Ltd.. This data can be used to generate usage profiles under a pseudonym. Cookies may be used for this purpose. The data collected with Hotjar technologies is not used for the purpose of personally identifying visitors to this website and will not be conflated with personally identifiable information about the bearer of the pseudonym without the explicit consent of the individual in question. You may opt-out from having Hotjar collect your information when visiting a Hotjar Enabled Site at any time by visiting the Hotjar Opt-out page and clicking 'Disable Hotjar' or enabling Do Not Track (DNT) in your browser.

11. Data transmission

Your data will not be transmitted to third parties as a general rule unless we are legally obligated to do so or the transfer of data is necessary for implementing the contractual relationship or you have given prior express consent to have your data transferred.

External service providers and affiliated companies, such as online payment vendors or shipping companies tasked with delivery, will only receive your data to the extent necessary to process your order. In these cases, however, the extent of data transmitted is kept to the necessary minimum. If our service providers come into contact with your personally identifiable information, we will make sure that this complies with the regulations of data protection laws in the same way through the course of processing the order in accordance with article 28 of the GDPR. Please note the vendor's respective data privacy policy as well. The respective vendor is responsible for the content of third-party services, although we review services for compliance with legal requirements to a reasonable extent.

We emphasize processing your data within the EU/EEA. However, it may happen that we use service providers who process data outside the EU/EEA. In these cases, we make sure that a reasonable level of data protection is established with the recipient before transmitting your personally identifiable information. This means that a level of data protection is reached through EU standard contracts or an adequacy decision that is comparable to the standard within the EU.

12. Data security

We have taken extensive technical and operational security precautions to protect your data from being accidentally or intentionally manipulated, lost, destroyed, or accessed by unauthorized persons. Our security measures are reviewed regularly and updated in keeping with technological advances.