Privacy Policy

These Terms of Service (“Terms”) are a binding legal agreement between you and Tulia that Tulia (“We” or “us”) values you as our member and recognizes that you put your trust in us by using Tulia services. This Privacy Policy describes how we process personal information in relation to your use of the Tulia Platform

  1. CATEGORIES OF PERSONAL INFORMATION WE COLLECT

1.1 Information Needed to Use the Tulia Platform.

When you use the Tulia Platform, we collect the following kind of personal information from you as needed. Without it, we may not be able to provide all services requested. This information includes:

  1. Contact, Account, and Profile Information. Such as your first name, last name, phone number, address, email address, your emergency contact and profile photo.
  2. Identity Verification Such as images of your government-issued ID (as permitted by applicable laws), your ID number and a selfie to verify your ID.
  3. Payment Information such as your Mpesa number or your bank account details.

1.2 Information You Choose to Give Us.

You can choose to provide us with additional personal information. This information may include

  1. Additional Profile Information. Such as gender, bio and interests. Travel-related preferences and requests such as favorite destination and accommodation types, and special dietary and accessibility needs. This information is part of your public profile page and will be publicly visible.
  2. Other Information. Such as when you fill in a form, add information to your account, respond to surveys, post to community forums, participate in promotions, communicate with Tulia Support and other Members, import or manually enter address book contacts, provide your address and/or geolocation, or share your experience with us. This may include health information if you choose to share it with us.

1.3 Information Automatically Collected by Using the Tulia Platform and Our Payment Services.

When you use the Tulia Platform and Payment Services, we automatically collect personal and other information. This information may include:

  1. Geolocation Information. Such as precise or approximate location determined from your IP address, mobile or other device’s GPS, or other information you share with us, depending on your device settings. We may also collect this information when you’re not using the app if you enable this through your settings or device permissions
  2. Usage Information. Such as the pages or content you view, searches for Listings, bookings you have made, additional services you have added, and other actions on the Tulia Platform.
  3. Log Data and Device Information. Such as details about how you’ve used the Tulia Platform (including if you clicked on links to third-party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, and the pages you’ve viewed or engaged with before or after using the Tulia Platform. We may collect this information even if you haven’t created an Tulia account or logged in.
  4. Cookies and Similar Technologies as Described in Our Cookie Policy.
  5. Payment Transaction Information. Such as payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, IBAN information, your address, and other related transaction details.

1.4 Personal Information We Collect from Third Parties.

We collect personal information from other sources, such as:

  1. Third-Party Services. If you link, connect, or login to the Tulia Platform with a third-party service (e.g., Google, Facebook), you direct the service to send us information such as your registration, friends list, and profile information as controlled by that service or as authorized by you via your privacy settings at that service.
  2. Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as references, demographic data, or information to help detect fraud and safety issues from third-party service providers and/or partners, and combine it with information we have about you. For example, we may receive background check results or fraud warnings from identity verification service providers for use in our fraud prevention, security investigation, and risk assessment efforts. We may receive information about you and your activities on and off the Tulia Platform, or about your experiences and interactions from our partners. We may receive health information, including but not limited to, health information related to contagious diseases.
  3. HOW WE USE INFORMATION WE COLLECT

2.1 Provide, Improve, and Develop the Tulia Platform

We may process this information to:

  1. enable you to access the Tulia Platform and make and receive payments,
  2. enable you to communicate with other Members,
  3. process your request,
  4. perform analytics, debug, and conduct research,
  5. provide customer service training,
  6. send you messages, updates, security alerts, and account notifications,
  7. process, handle, or assess claims,
  8. personalize and customize your experience based on your interactions with the Tulia Platform, your search and booking history, your profile information and preferences, and other content you submit, and
  9. enable your use of our enterprise products and accommodation services.

2.2 Create and Maintain a Trusted and Safer Environment.

We may process this information to:

  1. detect and prevent fraud, spam, abuse, security and safety incidents, and other harmful activities,
  2. study and combat discrimination consistent with our Nondiscrimination Policy,
  3. conduct fraud prevention, security investigations, and risk assessments,
  4. verify or authenticate information provided by you,
  5. conduct checks against databases and other information sources, including background checks,
  6. comply with our legal obligations, protect the health and well-being of our Guests, Hosts, Hosts’ employees, and members of the public,
  7. resolve disputes with our members, including sharing information with your co-Host(s) or additional Guests about disputes related to your role as a co-Host(s) or additional Guests,
  8. enforce our agreements with third parties,
  9. determine eligibility for certain types of bookings, such as Instant Book
  10. comply with law, respond to legal requests, prevent harm, and protect our rights (see section 4.5),
  11. enforce our Terms and other policies (e.g., Nondiscrimination Policy,), and
  12. assess or evaluate your interactions with the Tulia Platform and information obtained from third parties. In limited cases, automated processes, which analyze your account and activities on the Tulia platform as well as information in relation to activities on and off the Tulia platform that can be associated with you, could restrict or suspend your access to the Tulia Platform if such processes detect activity that may pose a safety or other risk to Tulia, our community, or third parties.

2.3 Provide, Personalize, Measure, and Improve our Advertising and Marketing.

We may process this information to:

  1. send you promotional messages, marketing, advertising, and other information based on your preferences and social media advertising through social media platforms,
  2. personalize, measure, and improve our advertising,
  3. administer referral programs, rewards, surveys or other promotional activities or events sponsored or managed by Tulia or its third-party partners,
  4. analyze characteristics and preferences to send you promotional messages, marketing, advertising, and other information that we think might be of interest to you,
  5. invite you to events and relevant opportunities, and
  6. send, with your consent, promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences.

2.4 Analyzing and Sharing Your Communications.

We may review, scan, or analyze your communications on the Tulia Platform for reasons outlined in the “How We Use Information We Collect” section of this policy, including fraud prevention, security investigations, risk assessment, regulatory compliance, product development, research, analytics, enforcing our Terms of Service, and customer support purposes. For example, as part of our fraud prevention efforts, we scan and analyze messages to mask contact information and references to other sites, and subject to applicable law, we scan and analyze all images uploaded by users to the Tulia platform in message threads, profiles, listings, and experiences for certain illegal or inappropriate activities (such as evidence of child exploitation) for the purpose of identifying and reporting content violations to appropriate authorities. In some cases, we may also scan, review, or analyze messages to debug, improve, and expand product offerings. We use automated methods where reasonably possible. Occasionally we may need to manually review communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools. We will not review, scan, or analyze your messaging communications to send third-party marketing messages to you and we will not sell reviews or analyses of these communications. We may also share your communications as set out in the “Sharing & Disclosure” section.

2.4 Analyzing and Sharing Your Communications.

Personal information is used to enable, or authorize third parties to use, Payment Services, such as to:

  1. detect and prevent money laundering, fraud, abuse, and security incidents, as well as conduct risk assessments,
  2. comply with legal and compliance obligations (such as anti-money laundering regulations and sanctions enforcement),
  3. enforce the Payment Terms and other payment policies, and
  4. provide and improve Payment Services
  5. SHARING & DISCLOSURE

3.1 Sharing With Your Consent or at Your Direction.

Where you provide consent, we share your information as described at the time of consent, such as when authorizing a third-party application or website to access your Tulia account or participating in promotional activities by Tulia partners or third parties.

Where permissible under applicable law, we may use certain information about you, such as your email address, that we share with social media platforms after de-identifying it to generate leads, drive traffic to Tulia, or otherwise promote our products and services.

3.2 Sharing Between Members.

To help facilitate bookings or other interactions between Members we may share information in situations such as:

  1. Between Guest(s) and Host(s) when:
    • A booking request is made, when there is a co-host, or a dispute is submitted, such as profile, name, cancellation history, review information, age of guest (unless prohibited by applicable law), dispute outcome (when applicable), and other information you choose to share and submit.
    • A booking is confirmed, additional information is shared to assist with coordinating the trip, such as profile photo and phone number.
    • You as a Host have a confirmed booking, certain information is shared with the Guest (and any additional Guests they invite, if applicable) to coordinate the booking, such as your profile, full name, phone number, and Listing address.
    • You communicate with a member, such as your name, profile picture, and message content.
  2. Between Hosts when:
    • You accept an invitation to host with another Member, you authorize those other Member(s), such as co-Hosts, to access and update your information and Member Content, such as certain information like your full name, phone number, Listing address, calendar, Listing information, Listing photos, and email address.

3.3 Information You Publish in Profiles, Listings, and Other Public Information.

You can make certain information publicly visible to others, such as:

  1. Reviews, ratings, and other public feedback
  2. Content in a community or discussion forum, blog, or social media post.
  3. We may also display listing details on third-party sites, platforms and apps.

3.4 Host Service Providers.

Hosts may use third-party services to help manage or deliver their services, such as cleaning services or lock providers. Hosts may use features on the Tulia Platform to share information about the Guest (like check-in and check-out information, Guest name, Guest phone number) with such third-party service providers.

3.5 Complying with Law, Responding to Legal Requests, Preventing Harm and Protecting Our Rights.

We may disclose your information to courts, law enforcement, governmental or public authorities, tax authorities, authorized third parties, or other Members, if and to the extent we are required or permitted to do so by law or where disclosure is reasonably necessary to: (i) comply with our legal obligations, (ii) comply with a valid legal request (such as a subpoena or court order) or to respond to claims asserted against Tulia, (iii) respond to a valid legal request relating to a criminal investigation to address alleged or suspected illegal activity, or to respond to or address any other activity that may expose us, you, or any other of our users to legal or regulatory liability, (iv) enforce and administer our agreements with Members, including our Terms, (v) protect the rights, property or personal safety of Tulia, its employees, its Members, or members of the public.

  1. Where appropriate, we may notify Members about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon or harm to Tulia, our Members, or expose Tulia to a claim of obstruction of justice.
  2. Where legally required or permissible according to applicable law, we may disclose Hosts’ and/or Guests’ information to tax authorities or other governmental agencies for the purpose of the tax authorities’ determination of proper compliance with relevant tax obligations. Relevant tax obligations include Tulia’s tax obligations on its service fees, its facilitation of taxes on accommodations and withholding taxes, and Hosts’ individual tax obligations. Information that may be disclosed includes, but is not limited to, Host and Guest names, listing addresses, Host addresses, tax/business identification number(s), date of birth, and/or contact information, property parcel identification numbers, payout information, transaction dates and amounts, number of nights and Guests booked, gross and net booking value and payout amounts, taxes collected by Tulia on behalf of Guests and Hosts, to the extent any of this information is known by Tulia.
  3. In jurisdictions where Tulia facilitates or requires a registration, notification, permit, or license application or number of a Host with a governmental authority, we may share information of participating Hosts with the relevant authority, both during the application process, when the Listing is published, and periodically thereafter, such as the Host’s full name and contact details, Accommodation address, tax identification number, registration, permit, or license number, Listing details, reservation information, and number of nights booked subject to applicable laws.

3.6 Programs with Managers and Owners

We may share personal information of Hosts and Guests with landlords, management companies, homeowners’ associations, property owners, and/or property managers (“ Building Management”), such as booking information and information related to compliance with applicable laws, in order to facilitate programs with Building Management. For example, guest booking and personal information, including guest contact information, may be shared with the Building Management of the building, complex, or community where a host lives and/or the listing is located to facilitate hosting services, compliance with applicable laws, security, billing, and other services

3.7 Host Information Provided to Tulia for Work Customers

If a booking is designated as being for a business or work purpose and (1) is made by a Guest affiliated with an Enterprise and (2) the Enterprise is enrolled in Tulia for Work, we may disclose information related to the booking to the Enterprise (e.g., name of the Host, Accommodation address, booking dates, listing details, etc.) to the extent necessary for the adequate performance of Tulia’s contract with the Enterprise and to provide the services. At the request of the Enterprise or the Guest, we may also share this information with third parties engaged by the Enterprise to provide support services.

3.8 Service Providers

We share personal information with affiliated and unaffiliated service providers (including their service providers) to help us run our business and for their compliance purposes, including those that help us: (i) verify your identity or authenticate your identification documents, (ii) check information against public databases, (iii) conduct background checks, fraud prevention, security investigations, and risk assessments, (iv) perform product development, maintenance, and debugging, (v) allow the provision of the Tulia Services through third-party platforms and software tools (e.g., through the integration with our APIs), (vi) provide customer service, advertising, or payments services, (vii) offer additional services you select, (viii) process, handle, or assess insurance claims or similar claims, or (ix) review, scan, and analyze communications on the Tulia Platform for certain purposes (such as evidence of child exploitation. These providers are contractually bound to protect your personal information and have access to your personal information to perform these tasks. Other Members can use services other than Tulia to process your data. These can include email or reservation management software. Such services are outside of Tulia’s control and will be subject to applicable laws around the world with varying levels of data protection

3.9 Business Transfers.

If Tulia undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer, or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence). In this event, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.

  1. OTHER IMPORTANT INFORMATION

4.1 Third-Party Partners & Integrations.

Parts of Tulia may link to third-party services. Tulia does not own or control these third parties. When you interact with these third parties and choose to use their service, you are providing your information to them. Your use of these services is subject to the privacy policies of those providers, including Google Maps/Earth Additional Terms of Use, Google Privacy Policy

4.2 TrueDepth API.

During the identity verification process on the iOS app our identity verification service provider makes use of the information collected using the device camera and the TrueDepth API provided by Apple. The data collected using the True Depth API is used in smile detection (on devices supporting True Depth) during the liveness capture when we prompt a user to smile. We use it for finding a face in 3D space for supported cameras. None of the information collected by the TrueDepth API ever leaves the user’s device nor is it persistently stored on the device.

  1. YOUR RIGHTS

You can exercise any of the rights described in this section consistent with applicable law.

5.1 Managing Your Information

You can access and update some of your personal information through your Account settings. If you connected your Tulia Account settings and unlink from that service in your Account settings. You are responsible for keeping your personal information up to date.

5.2 Data Erasure

You can request that your personal information be deleted. Please note that if you request deletion of your personal information, or if your account is suspended, terminated, or voluntarily closed:

  1. We may retain your personal information as necessary for our legitimate business interests, such as prevention of money laundering, fraud detection and prevention, and enhancing safety. For example, if we suspend your Tulia Account for fraud or safety reasons, we may retain information from that Tulia Account to prevent that Member from opening a new Tulia Account in the future.
  2. We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, Tulia and Tulia Payments may keep information for tax, legal reporting, and auditing obligations
  3. Information you have shared with others (e.g., Reviews, forum postings) may continue to be publicly visible on Tulia, even after your Tulia Account is canceled.
  4. Because we take measures to protect data from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.
  5. SECURITY

While no organization can guarantee perfect security, we are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unlawful or unauthorized access, loss, destruction, or alteration.

  1. CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time in accordance with applicable law. If we do so, we will post the revised Privacy Policy and update the “Last Updated” date at the top. In case of material changes, we will also provide you with notice of the modification by email at least thirty (30) days before the effective date. If you disagree with the revised Privacy Policy, you can cancel your Account. If you do not cancel your Account before the date the revised Privacy Policy becomes effective, your continued access to or use of the Tulia Platform will be subject to the revised Privacy Policy.

  1. CONTACT INFORMATION

For questions or complaints about this Privacy Policy or Tulia’s handling of personal information you can email us at bookings@tulia.co.ke or by call us on +254 726986986.

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