Privacy Policy

This Privacy Policy (hereinafter referred to as the ‘Policy’) is that of the company that publishes the HomeExchange.com Website (hereinafter referred to as ‘Website’):

HomeExchange.com Inc. 625 Massachusetts Ave, Cambridge, MA 02139

DPO contact: dpo@homeexchange.com

As the data controller,HomeExchange Inc is very committed to protecting your personal data and respecting your privacy.

The purpose of this Policy is to inform you of our practices regarding the collection, use and sharing of information that you may provide to us when you use our HomeExchange website, accessible at www.homeexchange.com/en/ (hereinafter referred to as ‘HomeExchange’).

We encourage you to carefully read this Policy, which applies when you use HomeExchange, in order to know and understand our practices regarding the processing of your personal data that we handle as well as your rights.

This Policy shall take effect as of  03/03/2023. It is subject to change at any time; in the event of substantial changes, we will inform you within a reasonable time period and, if necessary, request your consent again before it comes into effect. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Former versions:

03/12/2019: https://www.homeexchange.com/p/privacy-policy

Contents (Hyperlinks/formatting)

• 1. Purpose of the Policy
• 2. The information we collect
• 2.1. Required information that you transmit directly to us
• 2.2. Additional and optional information that you may send us
• 2.3. The information we automatically collect
• 3. The use of the data we collect
• 4. Data retention periods
• 5. The recipients of our data
• 5.1. HomeExchange members with whom you are communicating
• 5.2. Other companies belonging to our group
• 5.3. Business partners or third-party service providers
• 6. Storage of your information
• 7. Transfer of your data
• 8. Our use of cookies
• 8.1 Technical cookies
• 8.2 Audience measurement cookies
• 8.3 Advertising cookies
• 8.4 Social network / third-party cookies
• 9. How can I prevent the use of cookies?
• 10. Your rights
• 11. Exercising your rights
• 12. Your DPO contact
• 13. California Privacy Rights
• 14. Children under the age of 15
• 15. Data Security

1. Purpose of the Policy

To enable you to make the best use of our HomeExchange service, we may collect and use some of your information. This Policy aims to inform you of our practices and the reasons for them, in order to guarantee transparency for our users.

We undertake to use your information in compliance with the laws relating to the protection of personal data.

2. The information we collect

We collect and process the following data:

2.1. Required information that you transmit directly to us

Depending on the use of our services on HomeExchange, certain information must be provided. This is the data you transmit directly to us.

This information is required, for example, to create your account or to establish communication between your guests and yourself. These data are necessary so that we can provide you with the related service.

We, therefore, explain why we need it.

• 2.1.1 Information concerning your identity and contact details, such as your surname, first name, email and password. This information is required when you create your HomeExchange account.
• 2.1.2 Information concerning your accommodation, such as the nature of your accommodation (flat or house, principal or secondary residence), its location, surface area, number of bedrooms and bathrooms, number of beds, amenities and at least one photograph of your accommodation. This information is needed to add it to HomeExchange.
• 2.1.3 Information concerning your calendar, such as dates and periods of availability of your accommodation. This information is necessary when you wish to share your home with the HomeExchange community.
• 2.1.4 Bank details, such as your credit card number, visual ciphertext, expiry date. This information is required when you pay for a service online. These data, with the exception of the expiry date, are collected and processed directly by our payment service provider and we never store them. We keep the expiry date so that we can notify you when it expires and must, therefore, be renewed.
• 2.1.5 Evidence required for guarantees, such as proof of cancellation or damage you have suffered. These data may be transmitted to our financial partners.

2.2. Additional and optional information that you may send us

When using our services on HomeExchange, in order to benefit from an enhanced user experience, you may be asked to provide us with additional categories of information, the provision of which is optional, such as the following:

• 2.2.1 Additional information enriching your profile, such as your photograph, your date of birth, your telephone number, your description of yourself in your profile, languages spoken, some of your preferences, the various social networks on which you are registered.
• 2.2.2 Additional information enriching your accommodation, such as photographs of your home, your description of your home, your neighborhood.
• 2.2.3 Proof of identity, such as a copy of your identity card, passport, and proof of accommodation that you have added on HomeExchange. This information may enable us to verify that the information provided is accurate in order to reassure the HomeExchange community and protect our members from fraud.
• 2.2.4 Publications, friend lists and other social interactions, such as the groups and clubs you create or join, the friends you add, the comments you write and the ratings you give.
• 2.2.5 Private messaging. We also collect the private messages that you exchange with other members, but we treat them as confidential private correspondence in accordance with applicable regulations.

2.3. The information we automatically collect

Data may be automatically collected as you navigate our Website. We also automatically collect certain categories of information such as:

• 2.3.1 Information arising from your use of our HomeExchange services, such as the pages you visit, the accommodations you add to your favorites, the searches you save, your search terms, the home exchanges you make, the GuestPoints you earn or use, your response rate and time to questions asked by other members, your last login date.
• 2.3.2 Information concerning your equipment to access HomeExchange, such as your internet browser, screen resolution, operating system version and IP address.
• 2.3.3 Connection logs that correspond to our servers’ log files. The information contained may be your IP address, the type of browser used, your operating system, the pages viewed, the pages from which you came.
• 2.3.4 Cookies. We also use cookies that allow us to automatically collect certain information. For more information, see Section 8 (Our use of cookies) of this Policy.

3. The use of the data we collect

We use the data we collect for the following purposes:

Purpose	Legal Basis
3.1 to execute contracts concluded between you and us or between our business partners and us and to provide you with the services requested For example: - Payment of the deposit: we need your direct debit authorisation - Verification: we need your proof of identity and a proof of address in order to give you verified membership status - Guarantees: in the event of an incident, we need any proof related to the creation of a file, which must be kept until the file is resolved (photos, medical proof, repair and/or replacement estimates, etc.)	This processing is necessary for the performance of our respective contractual obligations, in accordance with our General Terms and Conditions of Use, accepted when creating your account and using HomeExchange.
3.2 to allow you to customize your profile in order to share more information with the HomeExchange community, socialize and reassure other HomeExchange members who would like to welcome you to their accommodation or be welcomed at your accommodation. For example: - Your description of yourself, the languages you state you speak, the photograph added to your account	This processing is necessary for the performance of our respective contractual obligations.
3.3 to verify your identity and to certify your member account in order to enjoy the trust of the other members of the HomeExchange community	This processing is necessary for the performance of our respective contractual obligations.
3.4 to answer your questions and assist you with your requests For example :  - Questions about how to use our services - To inform us of a dispute with another member - To lodge a complaint or request to exercise your rights	This processing is necessary for the performance of our respective contractual obligations.
3.5 to send you newsletters and notifications regarding HomeExchange community news and to notify you when there is activity on your account For example : - A member wants to become your friend - A member replied to your messages - A member adds your accommodation to their favorites	This processing is done based on your consent if you are not already a client of HomeExchange. If you are already a client, this processing could be done based on our legitimate interest. However, you can opt-out and ask us to stop sending these emails, by expressing your choice in your personal space (Once logged in, click on ‘My Profile’ then ‘Settings’) or by unsubscribing using the link at the bottom of our emails.
3.6 to send you emails and marketing messages	This processing is done based on your consent if you are not already a client of HomeExchange. If you are already a client, this processing could be done based on our legitimate interest.
3.7 to prevent fraud and illegal activities We have a legitimate interest in verifying certain suspicious behaviors of users on HomeExchange and carrying out verifications of information, in order to combat fraud (identity theft) abuse (creation of false accounts) and any illegal activity (hacking) or activity contrary to public order. We believe that you can reasonably expect us to perform these transactions and that they do not infringe on your rights and freedoms. We are likely to implement automated detection systems and to humanely verify the relevance of suspicions that our systems detect.	This processing is necessary in order to protect HomeExchange members and protect them from attempts at fraud, which is a legitimate interest
3.8 to analyze the use of our services We analyze the behavior of visitors to our website (interactions on the pages, use of features, search terms) in order to develop it, improve the relevance of search suggestions, modify our interfaces and our use paths when we detect that they are not intuitive enough for visitors. In addition, we regularly send questionnaires to all or part of our members in order to better understand their use of the site and help us improve it. Participation in these surveys is optional, and each time we specify the objective of the study, as well as the processing that will be made of the collected data.	This processing is necessary to provide you with better service and to allow our teams to make our website more attractive in order to facilitate your navigation, which is a legitimate interest.
3.9 to collect your payments or forward to you the sums collected on your behalf	This processing is necessary for the performance of our respective contractual obligations.
3.10 to store connection logs  For example : - IP address - type of browser used - operating system - pages viewed - pages of provenance, times - dates of visit to the site	This processing is based on a legal obligation to keep logs of connections to HomeExchange for a period of one year.
3.11 to perform profiling operations  Profiling consists, for example, of evaluating personal aspects, predicting behavior or preferences. We do several types of profiling: one to recommend accommodations that could potentially please our users, another to improve the order of accommodations appearing in our search engine, and, finally, we calculate a notion of similarity between accommodations.	This processing is based on the legitimate interest to strengthen and personalize the service offering according to your interests.
3.12 to participate in studies and research Because of our positioning and our business activity, we participate in university studies and research, for example, on the accommodation swapping market and the sharing economy. All your data are anonymised for the purpose of these studies and used for statistical purposes only.	This processing is anonymised.
3.13 to share your photos in our media We may use certain accommodation photos in the company's communication materials (newsletter, blog, advertising, etc.). These photographs are anonymous and do not reveal any private elements and are taken in respect of image rights.	Contract-based (terms of use). However you can opt out and ask us to stop using your medias if you do not want to share it
3.14 to receive commercial prospection messages from companies from our group The companies from our group may send you messages in order to present you new services that could be interesting for you.  We will only share your email address with these companies.	This processing is done based on your consent.

For processing performed on the basis of your consent, you may withdraw your consent at any time by removing the information from your account yourself. Our consent collection processes are currently being modified to correspond to personal data protection obligations. 

If the member wishes to modify their preferences in terms of privacy, they can do it through their account, in the section labeled “Settings”.

4. Data retention periods

We have the obligation to store your personal data during the duration of use of our service HomeExchange. If you asked for the erasure of your profile, we archive your personal data for a period of time of 3 months in case you would want to restore your profile during this period. We also can erase your account after a period of inactivity of 3 years.

After these retention periods, we only store information :

• for legal and accounting obligations, we may retain certain information for a maximum period of 10 years from their date (commercial limitation period);
• for evidentiary reasons: information collected for management and technical assistance purposes may be kept for a maximum period of five years from their date (civil limitation period);
• for commercial purposes: we may retain certain information for a maximum period of  3 years from our last contact with you except in the case that you unsubscribe to such messages.

At the end of the retention periods summarized above, we delete all your personal data in order to guarantee your confidentiality for future years.

The deletion of your personal data is irreversible and we will no longer be able to communicate them to you after this period. At most, we can only keep anonymous data for statistical purposes.

Please also note that in the event of litigation, we have an obligation to keep all the data concerning you for the duration of the processing of the file, even after the expiry of their retention periods described above.

5. The recipients of our data

5.1. HomeExchange members with whom you are communicating

When you exchange accommodation with another HomeExchange member, you will receive information from each other: this includes information about your identity, your contact details and the address of your accommodation.

5.2. Other companies belonging to our group

We will only share your data with those persons who are authorized to use it to implement our services. This may include our staff in charge of service implementation, accounting, marketing or even security of our premises. We may also pass on your data to certain members of our group or to technical service providers (e.g. hosting) in order to operate our service.

5.3. Business partners or third-party service providers

We work with third-party companies with whom we share some of your information, and who are:

• 5.3.1 Our service providers: we use a service provider only in connection with the performance of a contract between you and us or to provide and/or improve our services (for example, in connection with payments that are made on HomeExchange, or for newsletter management);

By subscribing to our damage and cancellation offers, we are required to transfer your data to our insurance partners, for the sole purpose of the fulfilling of their contractual obligations.  These data include:

• Identity information (name, last name...)
• Contact details (email, phone number…)
• Historical record of your relationship with HomeExchange (seniority, number of exchanges done…)

• 5.3.2 Our business partners: we have business partners who can advertise our services and whose offers you can agree to subscribe to;
• 5.3.3 Social networking platforms: we offer the possibility to use HomeExchange and to connect via social networks and can use them to offer you the best offers.

6. Storage of your information

We prefer to store your information, as much as possible, within the European Union. For example, our servers are located within the European Union.

However, we may use service providers who process the information we provide to them outside the European Union. When this happens, we first ensure that the recipient offers appropriate guarantees to process your information with a level of protection at least equivalent to the protection that European Union law offers you.

7. Transfer of your data

Unless strictly necessary and on an exceptional basis, we never transfer your data outside the European Union and your data is always hosted in the European Union. In addition, we make every effort to use only service providers who host your data within the European Union. 

Should our service providers nevertheless transfer your personal data outside the European Union, we take great care to ensure that they implement appropriate safeguards to ensure the confidentiality and protection of your data such as standard contractual clauses drafted by the European Commission or adequation decision.

8. Our use of cookies

We use cookies and trackers for various reasons:

8.1 Technical cookies

We need to store these cookies so that you can use the basic functions of our website and to offer you improved, personalized functions.

For example, technical cookies will allow us to know that you are connected, to offer you the language of your choice, to display the website according to your display preferences, to better manage the load on our servers, etc.

8.2 Audience measurement cookies

We place these cookies to better understand how you browse our website, what other website you came from, what content will get your attention, which pages you visit most regularly, etc. This allows us to improve our service.

8.3 Advertising cookies

We place advertising cookies to display ads that may be of interest to you. These advertising cookies collect your browsing habits on our website and/or on other websites on which these cookies are also present in order to create a profile of your interests. These third-party cookies are produced by the advertising agencies themselves.

For these advertising cookies, you can also indicate your objection to tracking cookies Your Online Choices: http://youronlinechoices.com/fr/controler-ses-cookies/, offered by the digital advertising professionals grouped within the European association EDAA (European Digital Advertising Alliance).

8.4 Social network / third-party cookies

We place social network cookies to allow you to share content on the leading social networks. These third-party cookies are produced by the social networks themselves.

9. How can I prevent the use of cookies?

You can block the use of cookies in several ways. You can check the type and use of the cookies in the following link: https://www.homeexchange.com/p/our-cookies.  To block cookies, scroll to the bottom of the page and click on the button “Cookies Settings” and select the cookies you would like to be blocked.

10. Your rights

Depending on your jurisdiction, you may have several rights with respect to your information that we possess:

Right of access	You may ask us to access any information we hold about you.
Right to rectification	You may ask us to correct your information. Most of the time, you can make corrections yourself when you are connected to our website.
Right to object	You may ask us to stop using your information when we do so because of a legitimate interest. You may also ask us to stop sending you direct marketing / prospecting messages. You can easily do this when you are connected to our website by going to the ‘My Profile’ tab and then ‘Settings’ or by unsubscribing by clicking on the link provided at the bottom of our emails.
Right to withdraw consent	Where you have given us your consent to use your information for a specific purpose, you may, at any time, decide to withdraw your consent and we will then stop using your information for that purpose. You can easily do this when you are connected to our website by going to the ‘My Profile’ tab and then ‘Settings’
Right to erasure or right to be forgotten	You may ask us, via email to our data protection officer, to delete your information or to stop using it. We can only do this when possible: sometimes we need your information to comply with the law or simply to provide you with our services.
Right to restriction of processing	You may ask our data protection officer by email to block the use of your information, i.e. to temporarily store it but to stop using it.
Right to portability	You may contact our data protection officer to request an export of your information in a reusable format.
Right to lodge a complaint	You may lodge a complaint with the authority responsible for protecting personal data if you believe that your rights have not been respected.

11. Exercising your rights

For a request to be taken into account, it is imperative that it be made directly by you at dpo@homeexchange.com. Any request that is not made in this manner cannot be processed. 

Requests cannot be made by anyone other than you. We may therefore ask you for proof of identity if there is any doubt about the identity of the requester.  

We will respond to your request as soon as possible, but no later than one month after receipt. The request can be processed in a maximum time of 3 months in case the request is technically complex or if we receive many requests at the same time.  

Please note that we can always refuse to respond to any excessive or unfounded request, especially if it is repetitive. 

If you believe that your rights under the data protection regulations  have been violated, you have the possibility to make a complaint before the French Supervisory Authority, the CNIL or before your local authority if you are not located in France. . In France, to the CNIL.

This complaint to the CNIL can be made via :

- The CNIL website: https://www.cnil.fr/en/plaintes

- By post to the following address CNIL - Service des Plaintes - 3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07

12. Your DPO contact

Protecting your information is important to us. That is why we have appointed a data protection officer. He or she is the best person to answer all your questions about personal data.

You can contact us in several ways:

By email: dpo@homeexchange.com

HomeExchange.com Inc. 625 Massachusetts Ave, Cambridge, MA 02139

13. California Privacy Rights

The California Consumer Privacy Act (CCPA) protects the data rights of residents of the State of California, USA.

At this time, HomeExchange is not subject to the CCPA. However, your privacy is important to us; we have therefore set ourselves high standards in data protection, and our Privacy Policy goes beyond many of the CCPA’s requirements.

The CCPA requires that companies post a link regarding a “Do Not Sell My Personal Information” enabling users to opt out of having their data sold to third parties. In our case, we NEVER sell any member data to any third party. Your accommodation and your information are safe with us.

If you live in California and you wish to have more visibility on how our Privacy Policy compares to the CCPA, please feel free to reach out to our Data Protection Officer: dpo@homeexchange.com California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website 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 email to [contact@homeexchange.com] or write to us at: [ Home exchange Boston, USA: 625 Mass Ave., Cambridge, MA 02139, United States of America].

14. Children Under the Age of 15

Our Website is not intended for children under 15 years of age. No one under age 15 may provide any personal data to or on the Website. We do not knowingly collect personal data from children under 15. If you are under  15, do not use or provide any information on this Website or through any of its features. If we learn we have collected or received personal data from a child under 15 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 15, please contact us at [contact@homeexchange.com].

15. Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. 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 certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.