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Coinsurf — Privacy Policy

Last updated: 30-08-2025

Table of Contents

1) Scope & Who We Are

This Privacy Policy explains how [Coinsurf Legal Entity Name] (“Coinsurf”, “we”, “us”) collects, uses, shares, and protects personal data when you use the Platform, websites, apps, or interact with us.

Controller: [Coinsurf Legal Entity Name], [Registered Address], [Country]. Contact: [privacy@coinsurf.com] • [support@coinsurf.com] • [Postal address].

Definitions: Listing (accommodation/experience offering), Host (Member who publishes Listings), Guest (Member who books/uses Host Services), Member (any registered user).

If you disagree with this Policy, please do not use the Platform.

2) Personal Data We Collect

We collect data you provide, automatically collected data, and data from third parties.

2.1 Information You Give Us: Account data, profile & Listing data, ID verification, communications, payment/billing (via processors).

2.2 Information You Choose: Optional profile fields, address book, surveys/forms, promotions, forums.

2.3 Automatic: Device/usage data, cookies/SDKs, diagnostics.

2.4 Third Parties: SSO providers, fraud/verification partners, integration partners, analytics/marketing partners, reviews.

2.5 Sensitive Data: We do not intentionally collect unless explicitly required; explicit consent or lawful basis needed.

3) How We Use Personal Data (Purposes & Legal Bases)

3.1 Provide, Improve & Develop Platform: enable features, accounts, bookings, payments, communications, analytics, support.

3.2 Trusted & Safer Environment: detect/prevent fraud, verify IDs, background checks, enforce Terms, resolve disputes, automated restrictions if needed.

3.3 Marketing & Communications: newsletters, promos, ads (with consent or opt-out). Referral/reward programs. Opt-out via Settings.

3.4 Taxes, Compliance, Enterprise Programs: handle occupancy taxes, enterprise/work bookings.

3.5 AI/Model Training: Default stance — no training on user content without explicit consent/opt-out.

4) Sharing & Disclosure

4.1 With Consent: per user authorization.

4.2 Between Members: Guests → Hosts (details for bookings); Hosts → Guests (details for coordination); co-hosts/team members; invited guests.

4.3 Profiles & Public Content: public profiles, Listings, reviews, forums/blogs.

4.4 Host-Used Services: limited Guest data shared to coordinate stays.

4.5 Compliance, Legal & Safety: disclose to authorities when legally required or to protect rights/safety.

4.6 Service Providers: hosting, analytics, payments, verification, support (Appendix B).

4.7 Affiliates: corporate group data sharing.

4.8 Social Media Audiences: hashed contact info for ads (opt-out available).

4.9 Occupancy Taxes: disclose booking/tax data where applicable.

4.10 Government Registration: share Host data for permits.

4.11 Enterprise Programs: disclose booking data to organizations.

4.12 Business Transfers: mergers/acquisitions.

4.13 Aggregated/De-identified: for analytics and insights.

5) International Data Transfers

When transferring internationally, we use SCCs, UK IDTA/Addendum, TIAs, or other safeguards. Contact us for copies.

6) Data Retention

Retention depends on purpose: account data (active + [X] months), content (until deleted + [X] months), logs ([X–Y] months), billing/tax ([X] years).

Data is anonymized/deleted when no longer needed.

7) Your Rights & Choices

Rights include access, rectification, deletion, portability, restriction/objection, withdraw consent, avoid automated decisions. Request via privacy@coinsurf.com or Settings.

Region-specific: GDPR (EU/UK), CPRA (California, incl. GPC honor, Do Not Sell/Share link), LGPD (Brazil), PIPEDA (Canada).

8) Cookies & Tracking

Used for authentication, preferences, analytics, advertising. Manage in banner/settings/browser/device. See Appendix A.

9) Security

Measures: encryption in transit, access controls, MFA, secure development, backups, incident response. No method 100% secure; use strong passwords + MFA.

10) Children’s Privacy

Platform not directed to under [13/16]. If data collected inadvertently, we will delete.

11) Automated Decision-Making (if applicable)

If used, we will explain logic, rights to review, contest, and human intervention.

12) Third-Party Links & Services

Links to third-party services follow their own policies.

13) Changes to This Policy

We may update the Policy; material changes notified with at least 30 days notice where required.

14) Contact Us

Coinsurf — Privacy Team

Email: privacy@coinsurf.com

Address: [Insert registered address]

Unresolved concerns: contact local authority.

Appendices

Appendix A — Cookie Policy: categories, purposes, controls, vendors, retention.

Appendix B — Sub-processors: published list at coinsurf.com/legal/subprocessors.

Appendix C — California Notice: categories, sources, purposes, disclosures, Do Not Sell/Share link, retention, non-discrimination.

Appendix D — Data Processing Addendum (DPA).

Appendix E — Regional Addenda (optional, per country).