Privacy Policy

Last update 14th August 2019

This document corresponds to Leavy's Privacy Policy for Leavy Homesharing and is intended to describe the processing of Happy Leavers personal data via Leavy Homesharing. Capitalized terms used in this document are defined in the Terms of Use accessible at https://leavy.co/terms

A. Conditions applicable to all Happy Leavers

(i) Collection of personal data: Leavy, in its relationship with the Happy Leaver, is required to process, for its own account, his/her personal data. This personal data is communicated to Leavy by the Happy Leaver (i) during his/her registration on the Site, or (ii) when using the Site. This information is necessary to enable Happy Leaver to use Leavy Homesharing.

(ii) Legal bases: by registering and using Leavy Homesharing, the Happy Leaver declares to accept the ToU and the SC applicable to him/her. These documents formalize a contractual relationship between the Happy Leaver and Leavy, serving in particular as a legal basis for the collection and processing of the Happy Leaver personal data by Leavy. Most of the means pursued are therefore based on the need to perform the contract with the Happy Leaver. In addition, Leavy collects the consent of the Happy Leaver for certain specific operations (cookies, commercial prospecting, geolocation). The details of the legal bases listed by purpose is available in sections B and C.

(iii) Personal data categories and processing purposes : Because the status of Happy Leaver or Host-on-Demand influences the nature of the data collected and the purpose of their processing, Leavy has developed specific processing conditions specific to each status. Those applicable to Happy Leavers are described in sections B below.

(iv) Happy Leavers rights:

  • Right to request from Leavy access to and rectification or erasure of personal data, or restriction of processing, or to object to processing as well as the right to data portability: in accordance with the law of 6 January 1978, amended, relating to data, files and freedoms ("Law No. 78-17") and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the "GDPR"), the Happy Leaver has the right to access his/her personal data, rectify, erase, request their portability, request the limitation of the processing, oppose or withdraw his/her consent. These rights may be exercised at any time by writing to Leavy at the following address: [support.uk@leavy.co]. The Happy Leaver may, at any time, have the right to lodge a complaint with a supervisory authority.
  • Guidelines for the retention, erasure and communication of data after the death of the Happy Leaver: a Happy Leaver has the right to set guidelines for the conservation, erasure and the communication of his/her personal data after his/her death. Any Happy Leaver can thus designate or not a third party who will be able to have access to the data communicated to Leavy. This third party can be designated by a Happy Leaver by writing an email, in this sense, to the following address [support.uk@leavy.co], indicating his/her last name, first name and e-mail address. If the Happy Leaver has not defined any guidelines regarding the fate of his/her personal data following his/her death, the Happy Leaver's heirs may ask Leavy to obtain any information useful for the liquidation and division of the estate by contacting to the following address: [support.uk@leavy.co]. The heirs may also, after the death of the Happy Leaver, obtain the cessation of any processing of personal data of the deceased.
  • (v) Retention period : the personal identification data of the Happy Leaver in relation to the ToU ( g . surname, first name(s), email address, mailing address) are kept for a period of three (3) years from the last contact from the Happy Leaver with Leavy. Audience measurement statistics are not retained for more than thirteen (13) months from collection. Data provided by a visitor who has not yet registered and provided data on his/her Property to evaluate the Guaranteed Revenue is kept for a period of three (3) years. However, at the end of the aforementioned deadlines, including as and when necessary from the removal request of the Happy Leaver, his/her personal data may be archived intermediately so that Leavy can meet hits legal retention requirements:
    • the contract concluded in the context of a commercial relationship will be kept for five (5) years from its conclusion;
    • the banking records will be kept for five (5) years from their release;
    • records relating to the management of orders will be kept for ten (10) years; and
    • the billing management documents will be kept for ten (10) years.

Certain data may be archived beyond the foreseen durations (i) in the event of litigation procedure in order to make it possible to establish the reality of the disputed facts; and / or (ii) for the purposes of the investigation, detection and prosecution of criminal offences for the sole purpose of enabling, as needed, the provision of such data to the judicial authority. Archiving implies that such data is anonymous and can no longer be consulted online but is extracted and kept on an autonomous and secure medium.

  • (vi) Recipients of personal data : Happy Leaver's personal data collected and processed by Leavy is strictly confidential. While taking this constraint into account, Leavy is required to temporarily and securely transfer to third parties certain personal data of the Happy Leaver when necessary to:
    • ensure the operation and maintenance of the Website (third-party recipients: web host and CRM (defined below) provider);
    • rent the Property (third-party recipients: City Explorer, Host-on-Demands, Property Rental platforms, photographers);
    • to respond to an administrative or judicial injunction (third-party addressees: administrative and / or judicial authorities).

Leavy uses a customer relationship management ("CRM") database, Pipedrive, to manage and track its services, including answering any questions asked by Happy Leavers. The CRM database includes personal data belonging to the Happy Leaver and Host-on-Demand with whom Leavy is already developing, or with whom Leavy wishes to develop, its services.

Leavy uses the following cookies:

Cookies Finality
Google Analytics Google Analytics is a Google web analytics tool that allows Leavy to better understand the behaviour of Happy Leavers.
  • (x) Minors : Leavy does not voluntarily seek to collect and process data of minors under fifteen (15) years old. If Leavy discovers that it has collected and processed personal data of minors under fifteen (15) without its knowledge, it will then take the necessary steps to delete the said data. If a parent has learned that his/her child under the age of eighteen (18) has sent his/her data to Leavy, he or she may contact Leavy immediately at the following email address data@leavy.co.

B. Categories of data processing activities

Categories of personal data Purposes of processing personal data Legal basis
Identification data ( e.g. name, email address) - to allow the Happy Leaver to create an account- to follow-up with the customer relationship, such as conducting satisfaction surveys, complaints management- to perform commercial solicitation operations- to inform the Happy Leaver in case of changes impacting the Site, the community and their operation - Performance of the contract
- Performance of the contract
- Consent
- Performance of the contract
Data in relation to bank details (IBAN) - to pay the Happy Leaver - Performance of the contract
Data related to connexion (cookies, IP address, geolocation) - to measure the audience- to perform commercial solicitation operations- to ensure that the content of the Website is optimized for Happy Leaver browsing and works satisfactorily - Consent
- Consent
- Consent
Data related to Happy Leavers' Properties (address, type of Property) - to manage invoices- to communicate data to Rental Properties - to manage litigation - Performance of the contract
- Performance of the contract
- Performance of the contract
Data related to Happy Leavers' travels - to manage invoices- to manage litigation - Performance of the contract 
- Performance of the contract