Kasa Living Privacy Policy
Last updated on June 11, 2024
Kasa Living Privacy Policy
Kasa Living, Inc. (“Kasa,” “we,”, “our,” or “us”) understands that privacy is important to our users. This Privacy Policy (the “Policy”) describes how we collect and use, and the circumstances in which we share, the information we collect from our website located at https://kasa.com (the “Site”), when you stay at one of our properties (each a “Kasa Property”), from any other online service on which we post this Policy, or from other sources. As used herein “Services” means all online and offline services we offer, including this Site, any mobile applications we offer, and our Kasa Properties.
Before you use or submit any information through or in connection with the Services, please carefully review this Policy. By accessing or using any part of the Services, you acknowledge that Kasa will collect, use, and disclose your information as further outlined in this Policy. We will continue to evaluate this Policy as we update and expand the Services and our offerings, and we may make changes to the Policy accordingly. Any changes will be posted here and you should check this page periodically for updates. If we make material changes to this Policy, we will provide you with notice as required by law. Your continued use of the Services will signify acceptance of the terms of the updated Policy.
Table of Contents
The Information We Collect
How We Use the Information We Collect
When We Disclose the Information We Collect
Online Analytics and Tailored Advertising
Your Choices
Data Retention
Security
Consent to Transfer
Children’s Privacy
Third-Party Links and Services
Changes to This Policy
Contact Us
1. The Information We Collect
We may collect information in different ways, such as when you provide information directly to us, when we passively collect information from you, such as through a browser or device, or from third parties.
a. Information we collect directly from you
We may collect information from you in a variety of ways, such as when you:
Register for or use a Kasa account;
Complete or update a Kasa account profile;
Book, lease, and/or visit a Kasa Property;
Fill out a survey or provide feedback;
Request certain features (e.g., newsletters, updates, and other products);
Make inquiries about our Services or otherwise communicate with us; or
Otherwise provide us with information on, through, or independent from the Services.
The information you provide directly to us may include, but is not limited to: (1) name; (2) personal email address; (3) business email address; (4) business address; (5) phone number; (6) identification information; (7) phone numbers; (8) demographic information; and/or (9) information related to your stay(s) and/or lease(s) at a Kasa Property.
b. Information that is passively or automatically collected
Device/Usage Information. We may automatically collect certain information about the computer or devices (including mobile devices or tablets) you use to access the Services. As described further below, we may collect and analyze information such as (a) IP addresses, geolocation information, unique device identifiers, IMEI and TCP/IP address, and other information about your computer or device(s), browser types, browser language, operating system, mobile device carrier information, the state or country from which you accessed the Services; and (b) information related to the ways in which you interact with the Services, such as: referring and exit web pages and URLs, platform type, the number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, statistical information about the use of the Services, the amount of time spent on particular pages, the date and time you used the Services, the frequency of your use of the Services, error logs, and other similar information. As described further below, we may use third-party analytics providers and technologies, including cookies and similar tools, to assist in collecting this information.
Cookies and Other Electronic Technologies. We may also collect data about your use of the Services through the use of Internet server logs, cookies and/or tracking pixels. A web server log is a file where website activity is stored. A cookie is a small text file that is placed on your computer when you visit a website, that enables us to: (i) recognize your computer; (ii) store your preferences and settings; (iii) understand the web pages of the Services you have visited; (iv), enhance your user experience by delivering content specific to your interests; (v) perform searches and analytics; and (vi) assist with security administrative functions. Tracking pixels (sometimes referred to as web beacons or clear GIFs) are tiny electronic tags with a unique identifier embedded in websites, online ads and/or email, and that are designed to provide usage information like ad impressions or clicks, measure popularity of the Services and associated advertising, and to access user cookies. As we adopt additional technologies, we may also gather additional information through other methods.
Please note that you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the "Help" section of your browser for more information (e.g., Microsoft Edge; Google Chrome; Mozilla Firefox; or Apple Safari). Please note that by blocking any or all cookies, you may not have access to certain features or offerings of the Services.
Location Information. We may collect different types of information about your location, including general information (e.g., IP address, zip code) and more specific information (e.g., GPS-based functionality on mobile devices used to access the Services), and may use that information to customize the Services with location-based information and. In order to do this, your location information may be shared with our agents and vendors. If you do not want us to provide you with these location-based features, you may disable them through your settings in the Services.
c. Information collected from third parties
We may obtain information about you from various third parties, such as data brokers, background check companies, social media companies, and researchers. For example, you may be able to access the Services through a social networking account, such as Facebook. You may also be able to “like” or post on our social media pages. If you access the Services through your social media account or follow us on social media, you may allow us to have access to certain information in your social media profile. This may include your name, profile picture, gender, networks, user IDs, list of friends, location, date of birth, email address, photos, videos, people you follow and/or who follow you, and/or your posts or "likes." Social networking sites, such as Facebook, have their own policies for handling your information. For a description of how these sites may use and disclose your information, including any information you make public, please consult the sites' privacy policies. We have no control over how any third-party site uses or discloses the personal information it collects about you.
To the extent permitted by law, we may, in our sole discretion, ask for and collect supplemental information from third parties, such as information about your credit from a credit bureau, or information to verify your identity or trustworthiness, or for other fraud or safety protection purposes.
Please note that we may combine information that we collect from you and about you (including automatically-collected information) with information we obtain about you from our affiliates and/or non-affiliated third parties, and use such combined information in accordance with this Policy.
2. How We Use the Information We Collect
We may use the information we collect from and about you for the following purposes:
For the purposes for which you provided it;
To provide the Services;
To respond to your questions and other inquiries;
To verify your identity and make a determination as to whether we will accept a reservation request, including conducting a background screening;
To provide you with notices about your Kasa account, including expiration and renewal notices;
To request your feedback;
For internal research and reporting;
To improve the content and features of the Services or develop new Services;
To contact you with information, surveys, or advertising that we believe may be of interest to you;
To personalize the content and advertising that you see on the Services or on other websites;
To enforce the legal terms that govern your use of the Services; and
To administer and troubleshoot the Services.
We may aggregate and/or de-identify information collected through the Services. We may use de-identified and/or aggregated data for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, sponsors, and/or others.
3. When We Disclose the Information We Collect
We may disclose your information in the following circumstances:
Consent
We may disclose your information to any third parties based on your consent to do so. This may include, without limitation, where you submit a testimonial or other type of user review about our Services for us to display and otherwise share publicly.
Affiliates
We may disclose your information with our affiliates.
Service Providers
We may provide access to or share your information with select third parties who perform services on our behalf, including without limitation marketing, support, building maintenance, data storage, analysis and processing, and legal services.
Property Partners
To facilitate your stay for legal purposes, we may provide certain information to property partners, such as names of guests, dates of reservations, and guest contact information.
Protection of Kasa and Others
We may disclose your information if required to do so by law or in a good faith belief that such access, preservation, or disclosure is permitted by this Policy or reasonably necessary or appropriate for any of the following reasons: (1) to comply with legal process; (2) to enforce this Policy or other contracts with you, including investigation of potential violations thereof; (3) to respond to claims that any content on the Services violates the rights of third parties; (4) to respond to your requests for customer service; and/or (5) to protect the rights, property, or personal safety of Kasa, its agents and affiliates, its users, and the public. This includes exchanging information with other companies and organizations for fraud protection, and spam/malware prevention, and similar purposes.
Business Transfers
As we continue to develop our business, we may buy, merge or partner with other companies. In such transactions, (including in contemplation of such transactions, e.g., due diligence) user information may be among the transferred assets. If a portion or all of Kasa’s assets are sold or transferred to a third-party, customer information (including your email address) would likely be one of the transferred business assets.
4. Online Analytics and Tailored Advertising
a. Online Analytics
We may use third-party web analytics services on our Services, such as those of Google Analytics. These service providers use the sort of technology previously described in the “Cookies and other electronic technologies” section to help us analyze how users use the Services, including by noting the third-party website from which you arrive, and provide certain features to you. We may use these service providers to collect on a real-time basis information on how you use and navigate our websites. This may include mouse movements and how you scroll through our website, but we do not collect keystroke data. The information (including your IP address) collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Services. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.
If you receive email from us, we may use certain tools, such as clear GIFs to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications.
b. Tailored Advertising
The Services may integrate third-party advertising technologies that allow for the delivery of relevant content and advertising on the Services, as well as on other websites you visit and other applications you use. These cookies and other tracking technologies may be placed on your computer, mobile phone, or other device to collect information about your use of the Services in order to (a) inform, optimize, and serve marketing content based on past visits to our websites and other sites and (b) report how our marketing content impressions, other uses of marketing services, and interactions with these marketing impressions and marketing services are related to visits to our websites. We also allow other third parties (e.g., ad networks and ad servers such as Google Analytics) to serve tailored marketing to you and to access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Services. We neither have access to, nor does this Policy govern, the use of cookies or other tracking technologies that may be placed on your computer, mobile phone, or other device you use to access the Services by non-affiliated, third-party ad technologies, ad servers, ad networks or any other non-affiliated third parties. Those parties that use these technologies may offer you a way to opt out of targeted advertising as described below. You may receive tailored advertising on your computer through a web browser. Cookies may be associated with de-identified data linked to or derived from data you voluntarily have submitted to us (e.g., your email address) that we may share with a service provider in hashed, non-human-readable form.
If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored marketing, you may visit the Network Advertising Initiative's (“NAI”) Consumer Opt-Out Link and/or the Digital Advertising Alliance's (“DAA”) Consumer Opt-Out Link to opt-out of receiving tailored advertising from companies that participate in those programs. To opt out of Google Analytics for Display Advertising or customize Google Display Network ads, you can visit the Google Ads Settings page. Please note that to the extent advertising technology is integrated into the Services, you may still receive advertising content even if you opt out of tailored advertising. In that case, the advertising content will just not be tailored to your interests. Also, we do not control any of the above opt-out links and are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms. If your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different computer or change web browsers, your NAI or DAA opt-out may no longer be effective. Additional information is available on NAI's and DAA's websites, accessible by the above links.
5. Your Choices
Depending on applicable laws, you have certain choices available regarding your information.
a. Your Kasa Account
You may request we delete, change or modify your information by emailing us at hello@kasa.com or writing us at Kasa Living, Inc at 155 E. 44th St, Floor 21, New York, NY 10017 USA.
b. Marketing Emails
To opt out of marketing e-mail communications, you may click the “unsubscribe” link in the marketing e-mails. Please note that we may still send you transactional communications, such as about your Kasa account, even if you opt out of marketing emails.
c. Cookies & Analytics
You can opt out of certain cookie-related and analytics processing by following the instructions in this Policy.
d. Nevada Residents
Under Nevada law, certain Nevada consumers may opt out of the sale of “personally identifiable information” for monetary consideration (as such terms are defined by Nevada law). We do not engage in such activity.
e. Residents of the United Kingdom or European Economic Area
Under applicable law, Kasa is considered the "data controller" of the personal data we handle under this Policy. In other words, Kasa is responsible for deciding how to collect, use and disclose this data, subject to applicable law. Our contact information appears in the “Contact Us” section below.
The laws of some jurisdictions such as the laws of the European Union and the United Kingdom require data controllers to tell you about the legal ground that they rely on for using, sharing, or disclosing of your information. To the extent those laws apply, our legal grounds are as follows:
Contractual Commitments: We may use, share, or disclose information to honor our contractual commitments to you, e.g. to comply with our Terms of Use, rental agreements, or other contracts between us.
With Your Consent: Where required by law, and in some other cases, we use, share, or disclose information on the basis of your consent.
Legitimate Interests: In many cases, we use, share, or disclose information on the ground that it furthers our legitimate business interests in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals, such as customer service, certain promotional activities, analyzing and improving our business, providing security for our Services, preventing fraud, and managing legal issues.
Legal Compliance: We need to use, share, and disclose information in certain ways to comply with our legal obligations.
Laws of the EU, European Economic Area, and the United Kingdom may permit you request that we:
provide access to and/or a copy of certain information we hold about you;
prevent the processing of your information for direct-marketing purposes; (including any direct marketing processing based on profiling);
update information that is out of date or incorrect;
delete certain information that we are holding about you;
restrict the way that we process and disclose certain of your information;
transfer your information to a third-party provider of services; and
revoke your consent for the processing of your information.
Please note, however, that certain information may be exempt from such requests in some circumstances, which may include needing to continue processing your information for our legitimate interests or to comply with a legal obligation. We may request you provide us with information necessary to confirm your identity before responding to your request.
To exercise any of these rights, please contact us as described in the “Contact Us” section below. In addition to those rights, you have the right to lodge a complaint with the relevant supervisory authority. However, we encourage you to contact us first, and we will do our very best to resolve your concern.
f. California Residents
This section supplements the information in our Policy above, and except as provided herein, applies solely to California residents. It applies to personal information we collect on or through the Services and through other means (such as information collected offline and over the telephone). It does not apply to (1) personal information we collect from our employees and job applicants in their capacity as employees of Kasa and job applicants for openings with Kasa; (2) personal information we collect from employees, owners, directors, officers, or contractors of businesses in the course of our provision or receipt of business-related services; or (3) personal information we process as a processor or service provider on behalf of our clients.
California law requires us to disclose information regarding the categories of personal information that we have collected about California consumers, the categories of sources from which the information was collected, the business or commercial purposes (as those terms are defined by applicable law) for which the information was collected, and the categories of parties with whom we share personal information.
As described further in the Policy above, in the preceding twelve months, we or our service providers may have collected the below categories of personal information for business or commercial purposes:
Identifiers: We may collect identifiers such as name, email address, phone number, postal address, government-issued identifiers, and other account information.
Commercial Information: We may collect commercial information, such as transaction data related to your use of the Services.
Financial or Payment Information: We or our service providers may collect payment or other financial information, such as when you make payments for a Kasa Property.
Professional and Employment Information: We may collect employment and business contact information, such as job positions and titles, and business contact information.
Internet or Other Network or Device Activity: We may collect network or device information, such as an IP address, unique device identifiers, advertising and app identifiers, browsing history, or other usage data.
Location Information: We may collect general location information (such as those inferred from an IP address or time zone). We may also collect precise geolocation information when you consent to such collection.
Health Information: We may collect health information, such as if you disclose any disabilities when searching for a Kasa Property.
Sensory Information: We may collect sensory information, such as audio recordings if you call our support department.
Personal Information Related to Protected Classifications: Our users may provide us with information that reveals information related to protected classifications, such as ethnicity or nationality.
Other Information that Identifies or Can Be Reasonably Associated With You: We may also collect other information that identifies or can be reasonably associated with you, such as when you send us communications, submit testimonials, or when we make inferences based on information we have collected about you.
We collect the categories of personal information identified above from the following sources: (1) directly from you; (2) through your use of the Services; and (3) third parties such as social media companies and background check companies.
As explained in our Policy, we collect the categories of personal information identified above for the following business and commercial purposes:
For the purposes for which you provided it;
To provide the Services;
To respond to your questions and other inquiries;
To verify your identity and make a determination as to whether we will accept a reservation request, including conducting a background screening;
To provide you with notices about your Kasa account, including expiration and renewal notices;
To request your feedback;
For internal research and reporting;
To improve the content and features of the Services or develop new Services;
To contact you with information, surveys, or advertising that we believe may be of interest to you;
To personalize the content and advertising that you see on the Services or on other websites;
To enforce the legal terms that govern your use of the Services; and
To administer and troubleshoot the Services.
Our Policy describes how we share personal information, such as when we share personal information with service providers, contractors (such as property partners), or as required by law.
If you are a California resident, you may have certain rights. California law may permit you to request that we:
Provide you the categories of personal information we have collected or disclosed about you in the last twelve months; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal information; and the categories of third parties with whom we shared personal information.
Provide access to and/or a copy of certain information we hold about you.
Delete certain information we have about you.
You may have the right to receive information about the financial incentives that we offer to you, if any. You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights. Certain information may be exempt from such requests under applicable law. We need certain types of information so that we can provide the Services to you. If you ask us to delete it, you may no longer be able to access or use the Services.
If you would like to exercise any of these rights, please submit a request to hello@kasa.com. You will be required to verify your identity before we fulfill your request. If you have an online account with us, logging into your account will serve to verify your identity and request, although we may request additional information if we believe your account has been compromised. If you do not have an account with us, or if we have reason to suspect that the security of your account is compromised, we will request additional information from you to match with our existing records to verify your identity, depending on the nature of the request and the sensitivity of the information sought.
You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization or a power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us.
Do Not Sell My Info. You have the right to opt-out of having your personal information sold. The California Privacy Rights Act (“CPRA”) amends the California Consumer Privacy Act to broadly define “sale” in a way that may include allowing third parties to receive certain information such as cookie identifiers, IP addresses and/or browsing behavior to add to a profile about your device, browser or you. Such profiles may enable delivery of interest-based advertising by such third parties within their platform or on other sites. Depending on how you use the Services, we may share the following categories of information for such interest-based advertising which may be considered a sale (as defined by the CPRA): (1) device information and identifiers, such as IP address and unique advertising identifiers and cookies; and (2) connection and usage information, such as browsing history or app usage. Although this obligation of the CPRA does not become effective until January 1, 2023, you may opt out of such tracking technologies by following the instructions in the Online Analytics and Tailored Advertising section above.
California Shine the Light. California law permits California residents to request and obtain from Kasa once a year, free of charge, a list of the third parties to whom Kasa may have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those third parties. Kasa does not share personal information with third parties for their own direct marketing purposes.
Do-Not-Track Notice. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We do not recognize or respond to browser-initiated DNT signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT.
6. Data Retention
We will retain your information for as reasonably necessary to provide the Services or until you delete or modify your information. We also reserve the right to retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
7. Security
We have implemented administrative, technical, and physical security measures to protect against the loss, misuse and/or alteration of your information. These safeguards vary based on the sensitivity of the information that we collect and store. However, we cannot and do not guarantee that these measures will prevent every unauthorized attempt to access, use, or disclose your information since despite our efforts, no Internet and/or other electronic transmissions can be completely secure.
8. Consent to Transfer
We currently maintain computer systems in the United States, so your personal information may be processed by us in the United States, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. By using the Services, you agree to this Policy and you consent to the transfer of all such information to the United States, which may not offer a level of protection equivalent to that required in the European Union, United Kingdom, or certain other countries, and to the processing of that information as described in this Policy.
9. Children’s Privacy
The Services are not designed for minors under 18. Only persons 18 years of age or older may use the Services. If we discover that an individual under 18 has provided us with personal information, we will close the account and delete the personal information to the extent required by the Children's Online Privacy Protection Act. We may, where permitted by law, retain certain information internally for purposes described in this Policy.
10. Third-Party Links and Services
The Services may contain links to or “frame” third-party websites, applications and other services (e.g., including retailers or merchants where you can make purchases). Please be aware that we are not responsible for the privacy practices of such other sites and services. We encourage our users to be aware when they leave our Services and to read the privacy statements of each and every site they visit that collects their information.
11. Changes to this Policy
We reserve the right to change this Policy at any time including to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology. Please check this page periodically for changes. Your continued use of the Services following the posting of changes to this Policy will mean you accept those changes.
12. Contact Us
If you have any questions about our Policy, you can contact us by emailing us at hello@kasa.com or writing us at Kasa Living, Inc., 221 Pine Street, Suite 500, San Francisco, CA 94104 USA.