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Privacy Policy

Last updated: November 10, 2020


Viewnary, Inc. is a corporation with its registered business address in the State of Delaware, 600 N Broad St, Suite 5 #509, in the city of Middletown, zip code 19709, United States (“Viewnary”, "us", "we").

Viewnary is an online Platform that connects and manages payments and payouts between Hosts who have properties equipped with unique views such as panoramas, scenic landscapes, skylines and any other unique environments, with Guests seeking to make use of such Listings for a specified amount of time for experiences in the form of Viewings.

By registering an account on Viewnary, you agree to be subject to this Privacy Policy.


1. Key Definitions

Definitions that are not provided in this Privacy Policy can be found in our Terms and Conditions.

Affiliates”: companies related by common ownership or control.

Aggregated information”: combined information about all of our Users, specific groups of Users, or categories of Users to the extent that individual Users are not identified or referenced.

Data controller”: Viewnary, the company responsible for the use and processing of personal information.

“Personal information”: data and information of an individual that is accessible to the data controller. This information is specific to any one User and can thus be used to identify such Users.

Third parties”: companies or persons not related by common ownership or control or other unrelated individuals.

“Viewing”: the act by which the Guest accesses the Host’s Listing to enjoy and experience the services offered by the Host.

"User": a person who successfully registers an account on Viewnary.

"Host": a User who owns and/or manages a Listing.

"Guest": a User who books a Listing on Viewnary.

“Platform”: Viewnary site, mobile application, and services.

"Listing": a property owned and/or managed by the Host, available on Viewnary.

2. What Viewnary Collects

2.1. Information that you provide.

When you access Viewnary, we collect, store, and process information, including personal information, which you provide. This includes, but is not limited to, when you:

  • Submit forms on the Platform while registering or updating your account, including ID and other verification information;

  • Use the Platform to search for or create Listings, book and pay for a Viewing, and other such interactions with Users and the Platform;

  • Link your Viewnary account to a third-party account, allowing us to collect the personal information that you have provided to that third-party account to the extent allowed by your settings with that third-party site;

  • Contact and communicate with Viewnary;

  • Share information with another User.

2.2. Information Viewnary collects.

We collect, store, and process information, including personal information, which you provide. This includes, but is not limited to:

2.2.1. Mobile Data

When using certain features of the Platform:

i) General information like IP address;

ii) More specific information like GPS-based functionalities. If you do not wish for your location to be tracked, you can disable the GPS or other location-tracking functions on your device.

2.2.2. Log Data

Information that is automatically recorded by our servers whenever you access or use the Platform, whether you have and are logged in to your Viewnary or not, such as your:

i) IP Address;

ii) The date and time you access or use the Platform;

iii) Data relating to hardware and software you are using;

iv) Surf history, based on cookies (see section 3.)

3. Cookie Policy - Cookies and other Tracking Technologies

3.1. We use cookies and appropriate technologies to personalize the content of our website, tailor ads to the user, measure ad performance and provide a better experience. By clicking OK or enabling an option in Cookie Preferences, you agree as described in our Privacy Policy. You can update your Cookie Preferences to change your preferences or withdraw your consent. 

3.2. When you visit a website, it may store or retrieve information in your browser, usually in the form of cookies. This information can be about you, your preferences or your device and is usually used to make the site work as expected. The information doesn't usually identify you directly, but it can give you a more personalized web experience. Because we respect your right to privacy, you can choose not to allow certain types of cookies. You can click on the different heading of sections for more information and change our default settings. However, blocking certain types of cookies may affect your experience with the site and the services we are able to offer. 

3.3. Strictly Necessary Cookies 

These cookies are necessary for the website to function and cannot be disabled in our systems. They are usually only set in response to your actions that resulted in a service request, such as setting your privacy preferences, logging in or filling out forms. You can set your browser to block or alert you to these cookies, but some parts of the site may not work as a result. 

3.4. Performance Cookies 

Cookies allow us to count the number of visitors and traffic sources so that we can measure and improve the performance of our website. This way we know which pages are the most and the least popular and how visitors navigate the website. All information these cookies collect is aggregated and therefore remains anonymous. If you do not allow these cookies, the information collected will not be used to improve the performance of the website. 

3.5. Functional cookies 

These cookies make it possible to improve functionality and personalization, such as videos and live chats. They are set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies, (some of) these functionalities may not work properly. 

3.6. Except as per this Privacy Policy, third parties may not collect information about Users’ online activities on Viewnary.

3.6.1. Third-Party Services and Social Plugins

Viewnary may use social plugins provided and operated by third parties. These third parties may retrieve the information you view on certain parts of the Platform. If you are logged into Viewnary via a third-party’s account, that third-party may be able to identify you, be able to link information about your visit to our Platform to your account with them, and may record your interactions with the social plugin. If you are not logged in via a third-party, that third-party will not be able to identify you.

3.6.2. Further details regarding the privacy policies of our third-party social plugins can be found below:

4. Grounds for Data Collection and Storage

4.1. Details reported on your identity document are collected for identity verification purposes in accordance with the Laws of the State of Delaware, the United States, and the European General Data Protection Regulation (GDPR).

4.2. The following GDPR legal grounds are invoked:

i) Permission;

ii) Implementation of an agreement with you;

iii) Legal obligations;

iv) Performing a task in the general interest;

v) Justified interest of Viewnary or a third party.

4.3. Citizen service numbers and other so-called special personal data will not be collected by Viewnary.

4.4. As per the principles set by the GDPR:

i) Your data will be stored for the shortest time possible; the GDPR does not stipulate an upper limit. In accordance with legal (national) obligations such as tax and anti-fraud law, such data may be archived for longer periods before being deleted. We may also archive data for purposes such as research and analytics. Viewnary generally stipulates a retention period of two (2) years after termination of your agreement with us (terminating your Viewnary account). Certain technical and organizational measures are implemented to protect your data, including encryption, anonymization, and limited access by employees.

ii) We do not intend to collect or process data of persons under the age of sixteen (16). As per our Terms and Conditions, so-called minors under eighteen (18) years of age are prohibited from creating an account on Viewnary.

5. How We Utilize Your Data

5.1. We utilize your personal data for the following purposes in correspondence with the legal grounds listed in section 4 above:

  • To enable you to access and use the Platform (grounds: ii);

  • To enable you to communicate with other Users, such as by sending them messages through Viewnary chat (grounds: ii or v);

  • To continuously enhance the Platform and Users’ experience through marketing/performance analytics, research, and providing customer service (grounds: v);

  • To ensure safe and trusted use of the Platform, such as by enforcing our Terms and Conditions, preventing fraud and harmful activity, and verifying provided personal information and Listing addresses against databases. We have no obligation to notify you of such activities occurring (grounds: iv or v);

  • To communicate and inform you of, amongst others, any support and administrative messages, updates, or other reminders (grounds: ii or v);

  • To communicate and inform you of, amongst others, marketing, and promotional messages. You have the right to unsubscribe from receiving such messages/notifications via your Viewnary account settings or by contacting us (grounds: ii);

  • To analyze cookies for our Platform in order to ensure our communications are in line with your personal preferences (grounds: i);

  • To comply with our legal obligations, resolve any disputes that we may have with the concerned parties, and enforce our agreements with third parties (grounds: ii, iii, or v).

5.2. Based on the legal grounds and purposes listed above in section 5.1., Viewnary or appointed third parties may also monitor your communications with other Users on the Platform. Such purposes include, but are not limited to, preventing fraud and other harmful activity.

5.2.1. Monitoring communications may also occur to help us expand and improve our product offering, user communication process, and overall functionality of the Platform.

5.2.2. We do not monitor your communications for sending third-party marketing messages to you, nor sell information of communications with third parties.

5.3. You understand and agree that Viewnary, in its sole discretion, may directly or through third parties monitor your communications either manually or via automation.

6. Personal Information Disclosure

6.1. Your personal information may be transferred, stored, used, and processed to/in countries outside of the United States of America ("USA") and/or the European Economic Area (“EEA”). Laws may vary from jurisdiction to jurisdiction, meaning that privacy laws may differ from your place of residence.

6.2. You understand and agree to the following:

  • Personal information from some parts of your public profile may be visible on parts of the Platform that are accessible to other Users and the general public;

  • Certain basic details are visible on a Host’s Listing page, including first name, profile picture, the approximate location of Listing on the map, calendar availability, Listing description, any additional information you provide that is publicly visible;

  • Other parts of the Platform and/or third-party sites may use parts of your public Listing page for marketing purposes;

  • Search engines may index a Host’s Listing page and profile and hence those may appear under search results;

  • If you send a booking request as a Guest, the following will be disclosed to the Host: your name and a link redirecting to your account’s profile page; contact details are only exchanged when a Host accepts a booking request;

  • Financial data such as billing and payout information is never disclosed to another User;

  • Ratings and reviews may be visible to other Users on a particular Listing.

6.3. You have the option to link your Viewnary account to a third-party social networking site account. We refer to a person’s contacts on these third-party sites as “friends”. When you create this linkage:

  • Some information from the linked accounts may be visible on your Viewnary profile;

  • Your friends and/or the third-party site may be able to view your activity on the Platform;

  • Your Viewnary profile page may embed a link to your profile on that third-party site;

  • To attempt to prevent fraud and other harmful activity, the information you provide from the linkage may be collected, processed, and transferred by us;

  • Your settings and authorizations on the Platform and the third-party site determine what information is available to Viewnary;

  • HTML widgets, amongst other tools, may be used to distribute parts of the Platform - such as a Host’s Listing - to sites of our business partners and affiliates. If a Listing is displayed on such sites, information from your Viewnary profile may also be visible.

  • Generally, your personal data will not be transferred outside the USA or EEA. However, if we engage third parties outside the USA/EEA, data processing may occur outside the USA/EEA for various purposes. We may provide personal information to these third parties if and only if they require this to provide their services. Viewnary will take measures to ensure international transfers comply with applicable legislation;

  • You understand and agree that we may access, store, and disclose your account information and content if required by law and for other reasons as stated in section 5;

  • Aggregated information and non-personal information may also be visible and disclosed for purposes including, but not limited to, marketing, industry analysis, and market analysis.

7. Business Transfers

7.1. In the event of a merger, acquisition, restructuring, divestment, or bankruptcy involving Viewnary, your personal information may be transferred, sold, or shared. You will be notified of such an event and whether a different Privacy Policy is implemented.

8. Editing your Personal Information and Account

8.1. You may edit, amend, or delete your personal information at any time. You may also terminate your Viewnary account as per our Terms and Conditions. Some publicly available content, such as ratings and reviews you post, may still be visible on the Platform after your account is terminated.

8.2. GDPR Article 17 - “The Right to be Forgotten” or “Right of Erasure” - governs the circumstances under which you may submit a request for personal data to be erased. The same Article also cites reasons for us to deny such a request or, if applicable, charge a discretionary fee for such erasure. You understand and acknowledge that it is your sole responsibility to be informed of your rights concerning personal data erasure.

8.2.1. Viewnary cannot delete your data in situations where we process your personal data in furtherance of our statutory obligations.

9. Personal Information Security

9.1. As above-mentioned, Viewnary takes measures to protect your personal information and data. However, we cannot guarantee and are not liable for any involuntary breaches, given that the Internet itself is not entirely secure.

10. Privacy on Third-party Websites and Resources

10.1. Third-party sites may implement their own cookies, web beacons, and other files on your device and thereby collect your personal information. You acknowledge and understand that Viewnary has no control over these third-party site practices, and is not liable for issues arising from them.

10.2. Google Maps/Earth mapping services, including Google Maps API(s), may be integrated into the Platform. Google’s terms and conditions and privacy policy govern your use of these services.

10.3. When you run the Viewnary mobile app on your device, we collect location data through GPS, Wi-fi, or cellular triangulation. We use this information to provide a location tracking service on our website. We maintain this data only so long as it is legal to provide our service. Out-of-date data is removed from our database.

11. California Consumer Privacy Act ("CCPA")

The CCPA is incorporated within the terms of Viewnary’s general Privacy Policy. Your rights under the California Consumer Privacy Act (CCPA) are limited if you are an employee, director, officer, or other staff of Viewnary, or if we process your information as part of a business-to-business transaction. For residents of the State of California, the CCPA provides certain additional privacy rights related to the collection of your personal data. It grants the rights for you to know about the personal information we collect from you, as well as the rights to have such collected personal information deleted in certain situations. The CCPA does not apply to personal information covered by certain sector-specific privacy laws. Personal information we keep may be exempt under the CCPA if that personal information is subject to other privacy laws.

11.1. Personal information

As per the CCPA, personal information is defined as information that “identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular” California consumer or household. Exclusions are publicly available information, consumer information that is de-identified (anonymous), or aggregate consumer information.

11.2. What personal information do we collect from you?

Our general Privacy Policy describes our collection and use of personal information. For CCPA purposes, we may collect the following categories of information:

  • Personal identifiers: this includes first and last name, address, telephone number, unique personal identifier, and signature;

  • Device and online identifiers: this includes online identifiers, IP address, email address, account user name, mobile/wireless number, social media profile, unique device identifier, and serial number, and other device information;

  • Government identifiers: this includes social security number, national identification number, other government-issued identification numbers, driver’s or operator’s license number, passport number, and copies of government IDs;

  • Financial information: this includes transaction information, financial account information used to validate your identity, account information about externally linked accounts, account login credentials, and other financial information;

  • Demographics: this includes the date of birth and certain income data;

  • Protected classification characteristics: this includes age, national origin, citizenship, nationality, marital status, sex, and veteran or military status. We do not collect information regarding gender identity, gender expression, or sexual orientation unless you provide it to us in connection with our products or services;

  • Internet and network activity: this includes chat messages or emails sent to us, online website tracking information, and data related to user activity, including browser visits and cookies;

  • Location data: we may receive information about your location and your mobile device, including a unique identifier for your device;

  • Sensory data: data such as audio data, e.g. a recording of your voice for training purposes when you call us;

  • Transaction history: this includes customer transaction history, such as bookings made, or trends;

  • Professional and employment information: this includes occupation, employer, and employment history;

  • Insights about you: this may include a customer profile relating to a person's preferences, behavior, and customer value.

11.3. How do we use your personal information?

We use your personal information for the purposes described in section 5 of our Privacy Policy. We may also use your personal information for any other purpose that we disclose at the time you provide, or when we collect, information under applicable laws and regulations.

11.4. Where do we get your personal information from?

In addition to the sources described in section 2 of our Privacy Policy, we may collect personal information from other Users, third parties, government entities, and others.

11.5. Who do we share your personal information with?

We may share personal information with other Users, third parties, or service providers you engage with on our site, and government entities.

11.6. Do we sell your personal information?

We do not sell information to third parties as defined under California Law.

11.7. Do I have the right to know about my personal information?

You have the right to know certain information about our collection, use, and disclosure of your personal information for the twelve (12) months prior to the date of your request. You also have the right to request that we provide you with specific pieces of your personal information. Certain exceptions exist for these rights.

After receiving your request and verifying your identity, we may provide you with information regarding the following:

  • The categories of personal information collected from you;

  • The types of sources of the personal information we collected;

  • Our business or commercial purpose for collecting personal information;

  • The categories of personal information we disclosed about you to a service provider;

  • The specific pieces of personal information we collected about you (data portability).

Viewnary will inform you if all or some of your request conflicts with federal or state law, or your personal information is subject to a CCPA exemption. We will respond to the part of your request that is not in conflict with such laws or exempt as per the CCPA. Section 12 of our Privacy Policy outlines your rights under the GDPR, which is completely independent of the CCPA.

11.8. Do I have the right to have my personal information deleted?

You have the right to request that we delete the personal information we have collected from you, subject to certain exemptions or exceptions.

11.9. How do I exercise my CCPA rights?

If you are a California resident and would like to submit a CCPA request, you may submit one by contacting us at privacy@viewnary.com. Only you, or a person you authorize to act on your behalf, may make a consumer request related to your personal information. Written permission must be provided to that person, and should state that they are authorized by you to make a request on their behalf. That person must also be able to verify their identity with us and provide us with their written permission. An individual to whom you have provided Power of Attorney pursuant to Sections 4000 – 4465 of the California Probate Code may also make a request on your behalf.

11.10. How will you verify my identity if I submit a CCPA request?

In order to verify your identity, we will obtain certain information you provided us and use it to verify your identity. If we are not able to verify your identity, we cannot respond to your request.

11.11. Are there CCPA non-discrimination rights?

We will not discriminate against you or otherwise punish you for exercising your CCPA rights.

11.12. Inquiries and support

Kindly contact us at privacy@viewnary.com to submit any inquiries or concerns with regards to the above-mentioned points.

12. Your Rights Under the General Data Protection Regulation (GDPR)

12.1. As per the GDPR, you have the statutory right to know what personal information and data has been stored by us, and to whom this data has been disclosed. You also have the following rights, to the extent that law permits:

  • The right to submit a complaint to the Data Protection Authority (DPA) or an equivalent authority;

  • The right to restrict data processing;

  • The right to data portability;

  • The right to submit an objection regarding our processing operations that we conduct in our own legitimate interests or those of third parties. Such processing operations are listed in section 5 of this Privacy Policy.

12.2. Kindly contact us at privacy@viewnary.com to submit any inquiries or objections with regards to the above-mentioned points.

13. Changes to This Privacy Policy

13.1. We may change this Privacy Policy at any time, at our sole discretion, and without prior notice. This includes how we collect and use your personal information. Certain material changes to the Privacy Policy will be communicated to you via the Platform or through email, and the “Last Updated” date at the top of this document will be updated accordingly. The date on which we send you an email regarding such a change will be deemed your date of receipt of that email.

13.2. It is your sole responsibility to review any changes to our Privacy Policy. If you do not agree to a changed Privacy Policy, you may not use the Platform and must terminate your Viewnary account.

14. Feedback

14.1. Viewnary highly appreciates any feedback or suggestions you may have regarding our Platform. Please do not hesitate to share your feedback by contacting us at feedback@viewnary.com.

14.2. You understand and agree that Viewnary has sole and exclusive ownership of any feedback you provide, and hence you irrevocably assign such ownership to us. This includes your right, title, and interest in such feedback, as well as all copyright, worldwide patent, trade secret, and rights relating to intellectual property, proprietary information, and morality. You also understand and agree to assign Viewnary your right to waive such moral rights.

14.3. You understand and agree that you must, at our request and expense, undertake any actions to help Viewnary obtain and maintain its intellectual property rights and other legal protections for such feedback.

15. Language

15.1. Viewnary’s Privacy Policy is written in the English language. You acknowledge that your knowledge of the English language is sufficient in order to understand our Privacy Policy.

15.2. Viewnary's Privacy Policy is available in other languages than English for Users that make use of the Platform features in other languages than English.

15.3. Viewnary is not liable for any incorrect or improper translation of this Privacy Policy into another language, which leads to a different meaning or interpretation of the provisions included in the Privacy Policy. In case of conflict between the terms stated in this Privacy Policy in English and other privacy policies made available by us in other languages, the terms stated in this Privacy Policy in English shall take precedence.