Safe Harbor

KOMFORTSTAY, INC. 
GENERAL EEA/CH SAFE HARBOR NOTICE


Updated April 11, 2016


In October 2015 the European Court of Justice ruled that the Safe Harbor Framework was invalid, meaning that it can no longer be utilized as a legal mechanism to transfer personal data from the EU to the US. The nature of the services provided by Komfortstay require the flow of personal data back and forth between the EU and the US. We want to reassure our users that we have adequate measures in place to ensure that we comply with EU data protection law when transferring personal data outside of the EU.


Effective December 24, 2012


SCOPE OF SAFE HARBOR CERTIFICATION 
Komfortstay, Inc. (“we”) recognize(s) that the European Community has established a data protection regime pursuant to Directive 95/46/EC (the “Directive”). The Directive applies to the European Economic Area (“EEA”). Switzerland has also established a data protection regime pursuant to the Federal Act on Data Protection (“FADP”). These regimes restrict companies in the EEA and Switzerland (collectively, “EEA/CH”) from transferring personal data about individuals in the EEA/CH to the United States, unless there is “adequate protection” for such personal data when it is received in the United States.


To create such “adequate protection” and allow its subsidiaries and business partners to overcome the restriction on international data transfers established by the Directive and the FADP, Komfortstay, Inc. adheres to the Safe Harbor Privacy Principles published by US Department of Commerce (“Safe Harbor Principles”) with respect to personal data about individuals in the EEA/CH that subsidiaries, customers and other business partners in the EEA/CH send to Komfortstay, Inc. (“EEA/CH Data”). More information on the Safe Harbor Principles and Komfortstay, Inc.’s scope of participation is available at http://export.gov/safeharbor/.


SCOPE OF THIS NOTICE 
This Notice applies to EEA/CH Data relating to data subjects residing in the EEA/CH (“EEA/CH Persons”) Komfortstay, Inc. receives from affiliated and unaffiliated companies, customers (including guests and hosts) and business partners, via our European-facing websites (including, but not limited to,www.Komfortstay.co.uk, www.Komfortstay.de, www.Komfortstay.es, etc.). This Notice and our Safe Harbor registration does not apply to data received throughwww.Komfortstay.com. This Notice does not apply to personal data that we receive in the context of employment with Komfortstay, Inc. or one of our subsidiaries; separate notices address such excepted situations. The English language version of this Notice constitutes the operative version of this Notice, and any translated versions are provided as a convenience.


CATEGORIES OF EEA/CH DATA 
We receive certain information from users of our platform, including current and former hosts, guests and members of the public who may search our platform, and from individual representatives of Komfortstay, Inc.’s corporate business partners, such as service providers, vendors and suppliers. Such EEA/CH Data includes, without limitation, names, addresses, phone numbers, email addresses, internet addresses, and any other personal data that are affirmatively provided to Komfortstay, Inc. in order to provide the platform or manage our business 
relationships.


PURPOSES 
We collect and use EEA Data for purposes of providing the platform to our users, transmitting marketing emails and performing other marketing activities, and conducting related tasks for legitimate business purposes.


DISCLOSURE 
We share EEA/CH Data with our subsidiaries, affiliates and contractors. We also share EEA/CH Data with other third parties as instructed by us and in order to comply with our binding contracts and as required or permitted by law. With respect to marketing e-mails from Komfortstay, Inc., EEA/CH Persons may opt-out by submitting an e-mail request to safeharbor@Komfortstay.com with “Opt-Out” in the subject line, or by following opt-out instructions that are contained in each marketing email. EEA/CH Persons may also send an email to this address to ask to opt-out of disclosures to third parties, but such a limitation on data sharing may make it difficult or impossible for Komfortstay, Inc. to provide services. We may also disclose EEA/CH Data if legally required or permitted by law and we have a legitimate business interest in such disclosure.


ACCESS AND REVIEW 
EEA/CH Persons whose EEA/CH Data Komfortstay, Inc. holds as a data controller may request access to, and the opportunity to update, correct or delete some or all of the EEA/CH Data that Komfortstay, Inc. holds about them. To submit such requests or raise any other questions, please contact the Komfortstay, Inc. Safe Harbor Contact as described below. Komfortstay, Inc. reserves the right to take appropriate steps to authenticate an applicant’s identity, charge an adequate fee before providing access and deny requests, except as required by the Safe Harbor Principles.


SAFE HARBOR CONTACT 
Please e-mail any comments or questions regarding our safe harbor compliance to safeharbor@Komfortstay. If you have a comment or question that cannot be resolved with Komfortstay, Inc. directly, you may contact the competent local data protection authority in your EEA/CH Member State if it falls within the scope of this Notice. As stated above, the English language version of this Notice constitutes the operative version of this Notice, and any translated versions are provided as a convenience.