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Last Modified: July 1, 2020.



As part of the Agency and Facilitation Services Agreement, Host-Guest Agreement, IML SLU (collectively "we", or "the Company") provides this Hosts' Data Privacy Notice ("Privacy Notice") to explain our practices regarding the collection, use, transfer and other processing of certain personal data about the hosts ("Host Data"), as described in more detail below.

Please note you are under a legal obligation to provide the Company with some of the Host Data (as specified below), whereas providing the remainder of the Host Data is subject to your own free will and consent and to your relationship with the Company.

This Privacy Notice applies to current and former Hosts.

It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.


In this Privacy Notice, you can learn about:

      I.        INTRODUCTION

     II.        HOST DATA












We encourage you to read the Privacy Notice carefully and use it to make informed decisions. By visiting the Company's websites, mobile apps or other online properties, or by creating an account through our Services, you hereby agree to the Privacy Notice.



During your contractual relationship with the Company, it is routine for us to collect, process and store Host Data. Although not an exhaustive list, this will include:  



We generally collect the Host Data directly from the Hosts. From time to time, the Company may receive personal information about the Hosts collected from third parties we do business with in the course of our business interactions, such as regulatory bodies.

In those circumstances, the Company will take reasonable steps to ensure that those third parties have represented to us that they have the right to disclose the Host Data to us. In other cases not currently anticipated, we will notify you of where the data came from unless you are already aware of this information.



The Company uses and otherwise processes Host Data to the extent necessary or appropriate for the following purposes:



The Company shares the Host Data, including as stated below:

These third party service providers have access to Host Data as needed to perform their functions, but they are not permitted to use it for other purposes. The Company also seeks to (i) exercise appropriate due diligence in the selection of such service providers, and (ii) require via contract or otherwise that such service providers maintain adequate technical and organizational security measures to safeguard the Host Data, and process the Host Data only as instructed by the Company. 



The Company takes great care in implementing and maintaining the security of your personal data. To ensure the safety of our users' information, and prevent unauthorized use of any such information the Company employs industry standard practices and procedures such as compliance checks to ensure the policy is being adhered, data protection impact assessments, internal audits of processing activities etc.

Individuals within the human resources, legal, finance and accounting, security, communications, and information technology departments will receive access to Host Data when necessary in connection with their job responsibilities, and subject to the Company's internal security framework.    

As an additional safeguard to, the Company employs a Data Protection Officer ("DPO"). The DPO has the power to insist on company resources for data protection matters and has as a deep knowledge of data protection regulation and law privacy requirements. The DPO's responsibility includes, among other things: privacy and security compliance advice, notify authorities of a data breach incident, conducting awareness and training programs, etc.  The DPO's contact information is listed below.



Since the Company operates globally, it may be required to transfer Host Data to service providers and affiliates in jurisdictions that outside the European Economic Area ("EEA").

These service providers and affiliates may use Host Data for the purposes described in Section III, including supporting payment processing, finance, accounting and human resources, global directory, and corporate compliance activities. The Company is taking ongoing measures to ensure that such service providers and affiliates have implemented appropriate safeguards to protect the security of Host Data.

The data protection and other laws of these countries may not be as comprehensive as those in the European Union − in these instances we will take steps to ensure that a similar level of protection is given to your Host Data and that such transfer is in accordance with EU privacy and data protection regulations. If you want to learn more about the details of these safeguards you should get in touch with us using the contact details at the bottom of this notice.



This section addresses certain rights you may exercise with respect to your Host Data. You can get more information in relation to your rights using the contact details below.

Right of access

You have the right to access the information we hold about you, including supplementary information about your Host Data.

Correcting or erasing your information

You have the right to ask us (and third parties to whom we transfer your personal information) to rectify your personal information if it becomes inaccurate or incomplete.

In addition, note that you are responsible to update the Company if there are any changes or inaccuracies in your Host Data. 

You may also have the right to have incomplete personal data completed, including by means of providing a supplementary statement. Whether or not this is appropriate in any particular case depends on the purposes for which your information is being processed.

You have the right to ask us to erase your personal information if:

We need to notify any third parties with whom we have shared your information that you have made a rectification or erasure requests. We will take reasonable steps to do this, but this may not always be possible or may involve disproportionate effort.

Restricting processing of your information

You have the right to restrict our processing of your personal information if:

Right to object to processing

You can object to our processing your personal data under certain circumstances including where processing takes place in line with the Company's legitimate business interests as set out above.  Where you object to processing, we must stop processing your personal data unless we can show that our legitimate ground for processing of your personal data overrides your interests or where we need to process the data to establish, exercise or defend legal claims.

Data portability

You have rights to obtain and reuse your personal data for your own purposes. This right only applies:

We can refuse your data portability request if the processing does not satisfy the above criteria.  Also, if the personal information concerns more than one individual, we may not be able to transfer this to you if doing so would prejudice that person's rights.


Kindly note that the above rights are not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse your request, for example, refuse your request where we need to process the data to exercise or defend legal claims. In addition, in certain instances, your Host Data may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.

You are able to submit a complaint to the applicable supervisory authority in relation to our processing of your personal data. We take our obligations seriously and we ask that any concerns are first brought to our attention, so that we can try to resolve this.



Except as otherwise permitted or required by applicable law or regulatory requirements, the Company endeavors to retain your Host Data only for as long as it believes is necessary to fulfill the purposes for which the Host Data was collected (including, for the purpose of meeting any legal, accounting or other reporting requirements or obligations), and as required under applicable laws and regulations. We may, instead of destroying or erasing your Host Data, make it anonymous such that it cannot be associated with or tracked back to you.



We reserve the right to change this Privacy Notice at any time, so please re-visit this page frequently. We will provide notice of substantial changes of this Privacy Notice on the Services and/or we will send you an e-mail regarding such changes to the e-mail address that you volunteered. Such substantial changes will take effect seven (7) days after such notice was provided on any of the above mentioned methods. Otherwise, all other changes to this Privacy Notice are effective as of the stated "Last Revised" date, and your continued use of the Services after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes.



If you have any general questions about the Services or the information that we collect about you and how we use it, please contact us via email at or by sending a letter to:

We will make an effort to reply within a reasonable timeframe. Please feel free to reach out to us at any time. If you are unsatisfied with our response, you can reach out to the applicable data protection supervisory authority.



This part of the Privacy Notice addresses the specific disclosure requirements under the California Consumer Privacy Act of 2018 (Cal. Civ. §§ 1798.100-1798.199) and the California Consumer Privacy Act Regulations by the Attorney General (collectively, "CCPA").

User Rights under the CCPA

The CCPA provides consumers with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.


Access to Personal Information

You may request, up to two times each year, that we disclose to you the categories and specific pieces of Personal Information that we have collected about you, the categories of sources from which your Personal Information is collected, the business or commercial purpose for collecting your Personal Information, the categories of Personal Information that we disclosed for a business purpose, any categories of Personal Information about you that we sold, the categories of third-parties with whom we have shared your Personal Information, and the business purpose for sharing your Personal Information, if applicable.


Deletion Requests

You have the right to request that we delete any Personal Information collected from you and retained, unless an exception applies.

Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers, subcontractors, and consultants to delete) your Personal Information, unless an exception applies.


Exercising Your Rights

You can exercise your rights by submitting a verifiable consumer request to our email address: or by sending a mail to our physical address specified in the "HOW TO CONTACT US" section.

Only you or a person authorized to act on your behalf may make a consumer request related to your Personal Information.

The request must:

         Provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.

         Describe your request with sufficient details to allow us to properly understand, evaluate, and respond to it.

         We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us.  We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.  We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

You may only request a copy of your data twice within a 12-month period.

If you have any general questions about the Personal Information that we collect about you how we use it, please contact us at


Response Timing and Format

Our goal is to respond to a verifiable consumer request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing within the first 45 days period. We will deliver our written response, by mail or electronically, at your option. Any disclosures we provide will cover only the 12-month period preceding the request. If reasonably possible, we will provide your Personal Information in a format that is readily useable and should allow you to transmit the information without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

In case of rejection, the response we provide will explain the reasons for which we cannot comply with your request.

Please note that these CCPA rights are not absolute and requests are subject to any applicable legal requirements, including legal and ethical reporting or document retention obligations.


Designating Agents

You can designate an authorized agent to make a request under the CCPA on your behalf if:

         The authorized agent is a natural person or a business entity registered with the Secretary of State of California; and

         You sign a written declaration that you authorize the authorized agent to act on your behalf.

If you use an authorized agent to submit a request to exercise your right to know or your right to request deletion, please mail a certified copy of your written declaration authorizing the authorized agent to act on your behalf using the contact information below.

If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.



Unless permitted by the CCPA, we will not:

         Deny you goods or services.

         Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

         Provide you a different level or quality of goods or services.

Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.


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