General

Point 11: Children's Privacy

The protection of children's personal data is a priority for the Company. The Roomwaiy.com Site and Services are not intended for minors, and the Company adopts a strict policy to ensure that no child's data is knowingly collected or processed without the required parental consent.

11.1. Age Restriction and Target Audience:

• The Roomwaiy.com Site and Services are exclusively intended for adults (persons 18 years of age and older) or individuals who have reached the age of legal majority in their jurisdiction of residence.
• Use of the Site and the making of Reservations are only authorized for adults capable of entering into a legally binding contract.

11.2. Prohibition of Knowing Collection:

• The Company commits not to knowingly collect Personal Data from children under the required minimum age (generally 16 in Europe or 13 under US laws, unless specific local legislation applies).
• If the Company becomes aware that a minor has provided Personal Data without the verifiable consent of their parents or legal guardians, the Company will immediately take steps to delete this information from its servers and databases.

11.3. Information Regarding Minors in a Family Reservation Context:

• Children's Personal Data may only be collected and processed when this information is provided by a parent or legal guardian as part of a Reservation.
• This information is strictly limited to the Personal Data necessary for the execution of the Accommodation Contract (examples: child's name, first name, and date of birth for determining hotel rates, room allocation, or identification with the Accommodation Provider).
• The parent or legal guardian providing this information guarantees to the Company that they have the necessary and legal consent to disclose the child's data for this purpose.

11.4. Parental Monitoring:

• Parents and legal guardians are encouraged to monitor their children's internet use and to help enforce this Policy by requesting the deletion of any unauthorized information.
• Any parent or guardian who has reason to believe that their minor child has provided Personal Data to the Company without consent must immediately contact the Customer Service or the Data Protection Officer (DPO) of the Company.

11.5. User Responsibility:

• By accepting these GTC/GTS and making a Reservation, the User confirms they are of legal age and legally capable. The User assumes full responsibility in the event of any misrepresentation regarding their age or the unauthorized disclosure of a minor's data.

Point 12: Disclosure of Your Information (Sharing with Third Parties)

The Company commits not to sell, rent, or trade Users' Personal Data for commercial purposes. Your information is only disclosed to third parties to the extent strictly necessary and for the legitimate purposes set out below.

12.1. Direct Reservation Partners (Accommodation Providers):
Disclosure to Accommodation Providers is essential for the execution of the Accommodation Contract. For the Reservation to be honored, the Company must transmit the User's Personal Data directly to the relevant Accommodation Provider. This information includes:

• Identification Data (Name, First Name, contact).
• Reservation details (dates, room type, special preferences, number of people).
• Limited payment information necessary for confirmation or prepayment, where applicable.

12.2. Third-Party Service Providers (Processors):
The Company may use third-party companies and individuals to facilitate its Services (processors within the meaning of the GDPR). These providers act on behalf of Roomwaiy.com and are contractually obliged to ensure a level of data security and confidentiality equivalent to that of the Company. This category includes:

• Payment Providers: For the secure processing of credit/debit card transactions and fraud prevention.
• Cloud Hosting and Storage Providers: For hosting the Platform's servers and databases.
• Analytics Service Providers: For analyzing Site usage and improving performance.
• Communication Services: Platforms for sending emails, SMS, or newsletters.
• Customer Support Services: Tools and systems used to manage User requests.

12.3. Commercial and Marketing Partners (With Consent):
Your information may be shared with business partners or third-party advertisers if you have given your explicit consent to receive offers from them. This may include:

• Advertising platforms for targeting promotions.
• Affiliate services for tracking commissions.

12.4. Business Transfers:
In the event that the Company is involved in a merger, acquisition, reorganization, asset sale, or bankruptcy proceeding, Users' Personal Data may be part of the transferred assets. The Company commits to notifying the User and ensuring that the new entity respects the current Privacy Policy.

12.5. Legal Requirements and Protection of Rights:
The Company may disclose your Personal Data if it believes, in good faith, that such action is necessary to:

• Comply with a Legal Obligation: To comply with a subpoena, court order, legal process, or any other applicable governmental requirement.
• Protect Rights and Safety: To protect the rights, property, or safety of Roomwaiy.com, its employees, its Users, or the public, including enforcing these GTC/GTS and detecting fraud.
• Security Investigations: To assist competent authorities in investigations relating to illegal or potentially illegal activities.

12.6. International Data Transfers:
Given the global nature of booking services, your information may be transferred to countries located outside your jurisdiction of residence or the European Economic Area (EEA). In such a case, the Company ensures that the transfer is framed by appropriate safeguards, such as:

• An adequacy decision by the European Commission.
• Standard Contractual Clauses (SCCs) adopted by the European Commission.
• Obtaining the User's explicit consent for the proposed transfer.

Point 13: International Data Transfer (Transfers Outside the Jurisdiction)

Due to the global nature of travel intermediation services and the technological infrastructure used to operate the Platform, the User's Personal Data is likely to be transferred to countries located outside their jurisdiction of residence, including countries outside the European Economic Area (EEA).

13.1. Necessity of the Transfer:
Transfers of Personal Data outside the jurisdiction are primarily carried out for the following reasons:

• Execution of the Accommodation Contract: The transfer is imperative if the Accommodation Provider selected by the User is located in a third country (e.g., a hotel booked in Asia by a European customer). The transfer is necessary for the conclusion and execution of the Reservation.
• Technical Infrastructure: The use of Cloud service providers, analytical tools, or customer support tools based abroad (e.g., servers in the United States, support centers in Asia).

13.2. Transfer Safeguards (Applicable to EEA/GDPR):
When Personal Data of Users based in the EEA or the United Kingdom is transferred to countries not offering a level of data protection considered adequate by the European Commission, the Company implements strict protection mechanisms to ensure that the data remains protected in accordance with European standards. These safeguards include, but are not limited to:

• Standard Contractual Clauses (SCCs): The signing of standard contractual clauses adopted by the European Commission with data recipients, obliging the recipient to maintain protection standards equivalent to the GDPR.
• Adequacy Decisions: Transfer to third countries that have been subject to an adequacy decision by the European Commission.
• Binding Corporate Rules (BCRs): For transfers within groups of companies, if the Company or the recipient has them.

13.3. Transfers Based on Exceptions (Derogations):
In cases where the above safeguards cannot be implemented (particularly when sending data to a foreign Accommodation Provider), the transfer may be carried out based on a derogation provided for by law, primarily:

• Explicit Consent: When the User has given their explicit consent to the proposed transfer, after being informed of the potential risks.
• Contractual Necessity: When the transfer is necessary for the execution of the contract between the User and the Company (e.g., finalizing the Reservation) or for the implementation of pre-contractual measures taken at the User's request.

13.4. User Responsibility (Transfer to Accommodation Provider):
The User acknowledges that by choosing to book accommodation in a third country, they necessarily accept the transfer of their Personal Data to that country so that the Accommodation Provider can honor the Reservation. The User is informed that the data protection laws in force in the Accommodation Provider's country may not offer the same level of protection as those in their jurisdiction of residence.

Point 14: Group Sharing (Affiliated Entities)

The Company is part of a group of companies (hereinafter the "Roomwaiy Group") and, for operational reasons, administrative efficiency, security, and to offer a more coherent service, the User's Personal Data may be shared with other entities that belong to the same Roomwaiy Group or that are under the same control.

14.1. Purposes of Internal Sharing:
Sharing information within the Group is carried out for the following purposes:

• Centralized Management: Ensuring centralized management and support for Reservations and User accounts.
• Technical Support: Allowing the Group's technical and IT teams to ensure the maintenance, improvement, and security of the systems and databases used by Roomwaiy.com.
• Compliance and Audit: Facilitating compliance with internal Group legal and regulatory obligations (audits, risk management).
• Cross-Service Marketing (Legitimate Interest): Offering the User travel or accommodation related services and products offered by other entities of the Group, unless the User has objected.

14.2. Categories of Shared Data:
The categories of data shared internally are limited to those necessary to achieve the aforementioned purposes and may include:

• Identification Data (Name, contact).
• Reservation history and account activity.
• Site Analysis and Performance Data.

14.3. Guarantee and Legal Basis:

• Legal Basis: This sharing is generally based on the legitimate interest of the Company to ensure the efficiency of its commercial operations within a group of companies.
• Guarantee: All entities in the Roomwaiy Group are contractually bound by the Privacy Policy of Roomwaiy.com and are required to apply data protection and security standards equivalent to those described in these GTC/GTS. Internal transfer is considered data processing on the same basis as if it were carried out by the Company itself.

14.4. Right to Object:
The User has the right to object to the sharing of their Personal Data with other Group entities for direct marketing purposes. To exercise this right, the User must contact the Company's DPO as indicated in Point 9.

Point 15: Your Personal Information at Roomwaiy.com (Detail of Collection and Purposes of Use)

The purpose of this point is to inform you exhaustively about the nature of the Personal Data that the Company collects from you and the precise purposes for which this data is processed, thereby ensuring complete transparency.

15.1. What Personal Data Do We Collect?

The Company collects several categories of information, necessary for the provision and improvement of its Services.

• Identification and Contact Data: This information is provided directly by the User during registration or Reservation. It obligatorily includes your name, first name, valid email address, phone number, postal address, and country of residence. This is essential for contacting you regarding your stay.
• Reservation and Transaction Data: This includes the specific details of your order, such as stay dates, desired room type, names of other travelers, special preferences requested from the Accommodation Provider (e.g., baby crib, accessibility), as well as the history of your past Reservations and their status (cancellation or modification). This data is directly provided by you and updated by our Partners.
• Financial Data (Limited): During payment, we collect information necessary for the transaction. This includes the type of payment card, its expiration date, and the last four digits of the card number. It is important to note that, for your security, full credit card numbers are not stored by Roomwaiy.com but are securely processed by our certified payment provider.
• Technical and Usage Data: This data is automatically collected when you use the Site. It includes your IP address, device identifiers (from cookies), browser type and version, operating system, the pages you visit, the search queries you perform on the Site, the duration of your visit, and the referring website that directed you to Roomwaiy.com.
• Communication and Feedback Data: We collect the content of emails exchanged with our Customer Support, the reviews and ratings you leave on Accommodation Providers, and, where applicable (if legally authorized and notified), recordings of phone calls, for quality and training purposes.

15.2. How (Purposes) Do We Use Your Information?

The collected information is used for specific and legitimate purposes, detailed below by the legal basis of the processing:

A. Execution of Contractual Services (Contractual Necessity): The primary use of your data is to enable the execution of obligations arising from the Reservation. Your Identification, Reservation, and Financial Data are used to process the Reservation, guarantee payment, and send you necessary confirmations and receipts. Furthermore, essential data is imperatively transferred to the Accommodation Provider so that they can honor your stay. Finally, we use this data to ensure effective After-Sales Service, capable of managing your queries, modifications, or cancellations.

B. Platform Improvement and Security (Legitimate Interest of the Company): As part of the continuous improvement of our services, we use your Technical and Usage Data to perform statistical analyses on the Site's effectiveness, browsing flows, and to identify and correct technical errors. We also use Financial Data and IP addresses to implement measures for fraud and platform abuse prevention. To enhance your experience, your Reservation and Technical Data may be used for personalizing the offer displayed on the Site.

C. Commercial and Marketing Communication (User Consent): Subject to having obtained your explicit consent, we use your Identification and Contact Data to send you direct marketing communications, such as newsletters, price alerts, or special promotions. You always retain the right to withdraw this consent and unsubscribe from these communications at any time.

D. Legal Compliance (Legal Obligation): We retain and use certain of your Personal Data (notably Transaction and Identification Data) for compliance with our legal obligations, such as the retention of tax or accounting records required by law, or to respond to legal injunctions or court orders.

Point 16: Your Rights as a User

By using the Roomwaiy.com Platform, the User benefits from contractual and legal rights, which are detailed below:

16.1. Right to Information and Transparency:
The User has the right to be clearly and transparently informed about:

• These General Terms and Conditions (GTC/GTS) before any Reservation.
• The essential characteristics of the accommodation service offered by the Accommodation Provider, including the description, prices, and cancellation policies.
• The complete identity of the Company (Roomwaiy.com) and the Accommodation Provider concerned by the Reservation.
• The total price, all taxes included, encompassing all applicable mandatory fees.

16.2. Contractual Rights Related to the Reservation:
The User has the rights arising from the Accommodation Contract concluded with the Accommodation Provider, subject to the specific cancellation and modification policies of the reservation:

• Right of Withdrawal/Cancellation: The right to cancel or modify a Reservation is governed strictly by the Accommodation Provider's policy as displayed at the time of Reservation. The User is entitled to a refund according to the terms of this policy.
• Right to Conforming Service: The User has the right to expect the Accommodation Provider to provide the accommodation service in accordance with the description made on the Site at the time of Reservation.
• Contractual Claim: In the event of non-conformity or a major problem during the stay, the User has the right to file a claim directly with the Accommodation Provider, and to inform Roomwaiy.com Customer Service for assistance.

16.3. Privacy and Data Protection Rights:
The User benefits from all rights concerning their Personal Data, as exhaustively set out in Point 9 (Your Privacy Rights) of these GTC/GTS. These rights notably include:

• The right to access and rectify their data.
• The right to erasure (right to be forgotten).
• The right to object to the use of their data for direct marketing purposes.
• The right to data portability.

16.4. Right of Recourse:
In case of a dispute with the Company regarding the application of these GTC/GTS, the User has the right to file a recourse or a complaint, according to the procedures provided for in Section VII (Applicable Law and Competent Jurisdiction).

16.5. Exercise of Rights:
To exercise their contractual rights related to a Reservation (cancellation, modification), the User must use the tools made available on the Site or contact Roomwaiy.com Customer Service. To exercise privacy rights, the User must follow the procedure specified in Point 9.

Point 17: Management of Your Information

The Company is committed to ensuring that the Personal Data it holds about the User is accurate, complete, and up to date. We implement procedures to ensure data quality and its secure destruction when it is no longer needed.

17.1. Data Accuracy and Updating:

• User Responsibility: The User is responsible for the accuracy and completeness of the information they provide to Roomwaiy.com. They are required to promptly update their Personal Data via their User account on the Site, or by contacting Customer Service, in case of any change (for example, change of email address or phone number).
• Maintenance by the Company: The Company strives to update Personal Data if it is informed of an inaccuracy (for example, following feedback from the Accommodation Provider or notification from the User).

17.2. Data Retention Period (Retention Policy):

• Limitation Principle: Personal Data is kept only for the period strictly necessary to fulfill the purposes for which it was collected (see Point 15) and in accordance with applicable legal and regulatory requirements.
• Reservation Data: Data related to a specific Reservation (contract) is generally retained for the duration of the contractual relationship, plus the legal statute of limitations period necessary for the establishment, exercise, or defense of legal claims (for example, often 5 or 10 years depending on the jurisdiction).
• Account Data: User account identification data is retained as long as the account remains active. In case of prolonged inactivity (duration defined by internal policy) or deletion requested by the User, the data is anonymized or securely destroyed, subject to minimum legal retention obligations.
• Marketing Data: Data used for direct marketing purposes is retained until the User has withdrawn their consent.

17.3. Destruction and Anonymization Procedures:

• At the end of the applicable retention period, the Company commits to securely delete or anonymize the Personal Data so that it can no longer be linked to the User.
• Anonymization allows the data to be used for aggregated statistical analysis (travel trends) without any possible individual identification.

17.4. User Access and Control:

• The User has direct means (account interface) to view and modify some of their information.
• The full exercise of User rights (access, rectification, erasure, objection, etc.) is governed by Point 9 (Your Privacy Rights) and must be initiated via the specified formal request procedure.

Point 18: Correction of Inaccurate or Incomplete Information

The User has the absolute right to require the Company to rectify or complete Personal Data concerning them that is inaccurate or incomplete without undue delay. This right is a key component of the right to rectification, as stated in Point 9.

18.1. User Obligation of Accuracy:
The User is the initial guarantor of the truthfulness and accuracy of the information they provide during registration and any Reservation. Any modification of their contact details or personal information (for example, change of email address or name) must be reported or carried out without delay.

18.2. Rectification Procedure:
To correct or complete their Personal Data, the User has two options:

• Via the User Account: The User is encouraged to use their Roomwaiy.com account interface to directly modify editable profile information (such as name, phone number, or email address). The rectification is then immediately taken into account in the system.
• Via Formal Request to the DPO: For information that cannot be modified directly online, or to exercise their right to rectification in a formal and documented manner, the User must address a written and dated request to the Company's Data Protection Officer (DPO), clearly specifying:
  • The User's identity.
  • The current and incorrect data.
  • The rectified or completed data.

18.3. Processing Timeframe:
The Company commits to proceeding with the rectification or addition of information as quickly as possible after receipt of the formal request and verification of the User's identity, and in any case within the legal timeframe of one month (unless a justified extension is needed).

18.4. Consequences of Inaccuracy:
The Company declines all responsibility for any consequence resulting from the provision of false, inaccurate, or incomplete information by the User. In case of a Reservation, incorrect data could lead to refusal of access by the Accommodation Provider or essential communication problems.

Point 19: Right of Access to Data and Portability

The Company guarantees the User the exercise of the rights of access and portability of Personal Data, in accordance with applicable data protection laws.

19.1. Right of Access to Data:

• Purpose of the Right: The User has the right to obtain confirmation from the Company that their Personal Data is being processed and, if so, to obtain access to the said data and receive a copy.
• Content of Access: This right gives access not only to the raw data but also to detailed information concerning the processing, notably:
  • The purposes of the processing (see Point 15).
  • The categories of Personal Data concerned (see Point 15).
  • The recipients or categories of recipients (see Point 12).
  • The envisaged retention period (see Point 17).
  • The existence of the right to request rectification or erasure.
• Modality of Exercise: The request for access must be addressed in writing (mail or email) to the Company's Data Protection Officer (DPO). The Company will provide a response and access within the legal timeframe (generally one month) after verifying the applicant's identity.

19.2. Right to Data Portability:

• Scope of Application: The right to portability applies only to Personal Data that the User has provided to the Company and when the processing is based on consent or the execution of a contract (Reservation), and is carried out using automated means.
• Purpose of the Right: The User has the right to receive their Personal Data in a structured, commonly used, and machine-readable format (e.g., CSV, XML).
• Direct Transfer: The User also has the right to obtain that their Personal Data be transmitted directly by the Company to another data controller, where technically feasible.
• Modality of Exercise: The request for portability must be addressed in writing (mail or email) to the Company's DPO. Following identity verification, the Company commits to providing the data in the required format within the legal timeframe.

19.3. Exceptions and Limitations:
The Company may refuse to grant the request or limit it if:

• The right of access or portability is likely to infringe on the rights and freedoms of others (e.g., disclosure of third-party data).
• The request is manifestly unfounded or excessive (in which case reasonable fees based on administrative costs may be charged).

Point 20: Data Retention and Erasure (Retention and Right to be Forgotten)

The Company applies the principle of storage limitation, which means that Personal Data is retained only for the period strictly necessary to fulfill the purposes for which it was collected, or to meet mandatory legal requirements.

20.1. Retention Principles:

• Duration Necessary for Contract Execution: Data related to your account and your Reservations (Name, contact details, order history) is retained for the entire duration of the active contractual relationship (as long as you have an active account or Reservation).
• Legal Statute of Limitations: After the end of the contractual relationship or account closure, certain data is securely archived and retained for the legal statute of limitations applicable to commercial disputes or tax and accounting obligations (often between 5 and 10 years, depending on the jurisdiction of the Company's headquarters). This data is subject to very strict access restrictions.
• Marketing Data: Data used for commercial prospecting or marketing purposes is retained until the User withdraws their consent or exercises their right to object.
• Technical Data: Connection and usage data (logs, IP) may be retained for shorter periods, generally for the duration necessary for fraud detection and security maintenance (often 12 to 13 months).

20.2. Right to Erasure ("Right to be Forgotten"):

• Purpose of the Right: The User has the right to request the erasure of their Personal Data without undue delay (right to be forgotten) when:
  • The data is no longer necessary in relation to the purposes for which it was collected.
  • The User withdraws their consent (and there is no other legal basis for the processing).
  • The User objects to the processing, and there are no overriding legitimate grounds for maintaining it.
  • The processing was unlawful.
• Exceptions to the Right to Erasure: The Company cannot proceed with the erasure of data when its retention is necessary for:
  • Compliance with a legal obligation requiring processing (e.g., tax obligations).
  • The establishment, exercise, or defense of legal claims.

20.3. Secure Erasure and Anonymization Procedure:

• When the retention period ends or an erasure request is accepted, the Company commits to making the personal data irreversibly anonymous (to use it for aggregated statistical purposes) or to destroy it securely (for example, by cryptographic erasure), ensuring that it can no longer be restored or linked to the User.
• The erasure request must be formally submitted to the Company's DPO, following the procedure described in Point 9.

Point 22: Right to Object to Processing

The User has the right to object, at any time and on grounds relating to their particular situation, to the processing of their Personal Data by the Company.

22.1. Objection to Processing Based on Legitimate Interest or Public Interest Task:

• Principle: The User has the right to object to the processing of their data when it is based on a legitimate interest of the Company (such as performance analysis, Site improvement, or intra-group sharing for administrative reasons).
• Consequence: Upon receipt of the objection, the Company must immediately cease processing the Personal Data, unless it demonstrates:
  • Compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the User; or
  • The necessity of the processing for the establishment, exercise, or defense of legal claims.
• Procedure: The objection must be formalized in writing to the Company's Data Protection Officer (DPO), and the User is invited to specify the grounds related to their particular situation that justify their objection.

22.2. Objection to Direct Marketing (Absolute Right):

• Principle: The User has the absolute and unconditional right to object at any time to the processing of their Personal Data for commercial prospecting or direct marketing purposes, including profiling to the extent that it is related to such prospecting.
• Consequence: When the User exercises this right, the Company immediately ceases all processing of their data for these purposes.
• Modality: The objection can be exercised via the unsubscribe link present in electronic communications or via a formal request to the DPO (as specified in Point 9).

22.3. Right to Object and Fees:
The exercise of the right to object is free of charge. If the objection concerns the use of Personal Data for a non-essential feature of the Service, this will not affect access to the main Reservation Service.

Point 23: Third-Party Websites, Partners, and Associated Cookie Policies

The Roomwaiy.com Site may contain links to other websites that are not operated or controlled by the Company (hereinafter the "Third-Party Sites"). This clause defines the Company's responsibility regarding these sites and the use of data by external partners.

23.1. Lack of Control over Third-Party Sites:

• The Company declines all responsibility for the content, privacy policies, security practices, or actions of Third-Party Sites. The presence of a link to a Third-Party Site does not imply any endorsement or affiliation of the Company with that site.
• The User acknowledges that access to these Third-Party Sites is at their own risk and must consult the specific terms and conditions and privacy policy of these sites before any use or provision of personal information.

23.2. Partners and Cookies (e.g., StapeHotels and PRIVISA LLC):

• Interactions with Partners: As part of its activities (marketing, analysis, or payment services), Roomwaiy.com may interact with partner entities, such as StapeHotels or PRIVISA LLC, which may participate in the use or collection of data on the Site.
• Shared or Independent Responsibility: These partners may operate as processors (acting on behalf of Roomwaiy.com) or as independent data controllers, particularly concerning the use of third-party cookies on the Site.
• Cookie Policy: When a partner such as StapeHotels or PRIVISA LLC uses cookies or tracking technologies on the Platform, this use is detailed in the Company's complete Cookie Policy. This Policy specifies the role of each party and the means available to the User to manage or refuse these technologies.
• Data Transfer: The User is informed that, within the framework of the use of technologies by these partners, certain Personal Data (notably technical and usage data) may be shared with them for the purposes of analysis, targeted advertising, or service management, in accordance with the User's consent.

23.3. Exclusion of Liability:
The Company cannot be held responsible for the data collection policies and practices of Third-Party Sites or Partners (including, but not limited to, StapeHotels and PRIVISA LLC) acting as independent data controllers. For any question or complaint relating to their privacy practices, the User must contact the entity concerned directly.

Point 24: Reasons for Using Tracking Technologies (Cookies, Pixels, and Tags)

The Company uses cookies, web beacons, tags, and other similar technologies (hereinafter collectively the "Tracking Technologies") on the Roomwaiy.com Platform and in electronic communications for clear and essential reasons. This use is always carried out in compliance with your consent and your rights.

24.1. Functional Necessity (Strictly Necessary):
These technologies are used to ensure the proper functioning of the Site and the provision of basic services. They are essential for:

• Authentication: Allowing you to log in to your account and remain logged in during your session.
• Cart and Reservation: Enabling the smooth running of the Reservation process, by temporarily recording your selection items (dates, room type) before confirmation.
• Security: Detecting and preventing fraudulent activities or Site abuse.
• User Preferences: Memorizing choices you have made (such as language, local currency, or text size) to personalize your experience.

24.2. Performance Improvement and Analytics (Analytical):
The use of these tools allows the Company to understand how the Platform is used and to constantly improve it. They serve to:

• Audience Measurement: Compiling statistics on Site traffic, the number of unique visitors, the most visited pages, and the average duration of visits.
• Process Optimization: Identifying bottlenecks or performance problems on the Site (for example, pages that load slowly) to correct them.
• Campaign Effectiveness: Measuring the success of marketing campaigns by identifying where users who make a Reservation come from.

24.3. Marketing and Targeted Advertising (Advertising):
These technologies allow us to offer you more relevant offers and to finance the Platform's services. They are used to:

• Personalized Advertising: Displaying advertisements for destinations or accommodation services likely to interest you, based on your browsing history and search preferences.
• Exposure Limitation: Preventing the repetitive display of the same advertisement.
• Conversion Tracking: Measuring whether an advertisement has led to a Reservation on the Site, in order to fairly compensate advertising partners.

24.4. User Control: Roomwaiy.com's Cookie Policy provides complete information on the types of Tracking Technologies used and offers the User clear mechanisms to consent, refuse, or withdraw their consent for non-essential cookies (analytical and advertising). The User always has the possibility to manage these settings via the Site's preference management tools or their browser settings.

Point 25: Third-Party Involvement in Tracking and Data Use

The operation of the Site and the provision of tailored services require collaboration with various external parties who utilize the Tracking Technologies (cookies, pixels, etc.) described in Point 24. These Third Parties fall into specific categories based on their function:

25.1. Types of Third-Party Entities Involved:

• Accommodation Providers (Partners): While their primary role is service delivery (Point 12.1), they may utilize tracking mechanisms when the User is redirected to their own booking pages or during co-branded marketing campaigns.
• Analytics Service Providers: Entities such as Google Analytics, which collect and process technical and usage data on our behalf to help us understand Site performance and user behavior (Point 24.2).
• Advertising and Marketing Partners: Third-party networks, ad servers, and marketing platforms that use tracking technologies to display relevant advertisements both on the Site and on external websites (retargeting), based on the User's inferred interests (Point 24.3).
• Payment Service Providers: Parties that securely process payment details and often use their own tracking technologies for security and fraud prevention purposes (Point 12.2).

25.2. Specific Role of Mentioned Partners (StapeHotels and PRIVISA LLC):

• The Company specifically draws the User's attention to the potential involvement of partners such as StapeHotels and PRIVISA LLC (and other similar entities) in the processing of data via tracking technologies.
• These entities may act as joint controllers or independent controllers for certain tracking activities, particularly those related to the analysis of User behavior, the optimization of advertising delivery, or the management of specific services provided to Roomwaiy.com.
• When acting as independent controllers, their data processing practices are governed by their own respective privacy and cookie policies, which the User is encouraged to review.

25.3. User Control Over Third-Party Tracking:

• The scope and nature of the tracking conducted by these Third Parties are fully detailed in the Company's separate Cookie Policy.
• The User maintains the right to manage and withdraw consent for non-essential third-party tracking, either through the Site's dedicated Consent Management Platform (CMP) or by adjusting their browser settings.

25.4. Company Liability Limitation:
While the Company requires all third-party processors to adhere to strict data protection standards (Point 10.2), Roomwaiy.com is not responsible for the data processing practices, security failures, or specific actions of independent Third-Party Controllers (including the mentioned partners) who may use tracking technologies on or through the Site.

Point 26: Changes to These Terms and Policies

The Company reserves the right to modify, update, or replace these General Terms and Conditions (GTC), the Privacy Policy, and the Cookie Policy (collectively, the "Policies") at any time, in response to changes in law, regulatory requirements, or changes to the Services offered by Roomwaiy.com.

26.1. Notification of Changes:

• Material Changes: For any material change (a change that significantly affects the User's rights, obligations, or the processing of Personal Data), the Company will notify the User in advance, using reasonable measures. These notification methods may include:
  • Sending an email notification to the primary email address associated with the User's account.
  • Posting a prominent notice or banner on the Site's homepage.
  • Notification upon login.
• Minor Changes: Minor changes (e.g., editorial corrections, updates to non-essential information) may be effective immediately upon posting the updated Policies on the Site, without separate notice.

26.2. Effective Date and Acceptance:

• The updated Policies will indicate the date of the last revision and will take effect on the "Effective Date" specified in the document.
• By continuing to access or use the Site or Services after the Effective Date of any modified Policies, the User acknowledges and agrees to be bound by the updated terms.

26.3. User's Right to Reject:

• If the User does not agree to the modified Policies, they must immediately cease using the Site and the Services.
• If the changes concern the processing of Personal Data and affect the legal basis of consent, the Company will seek new, explicit consent from the User.

26.4. Review Responsibility:
The User is responsible for regularly reviewing the most current version of the GTC, the Privacy Policy, and the Cookie Policy, which are always accessible via the appropriate links on the Site.

Full Legal References

This User Responsibility Policy outlines the obligations and expected conduct of all individuals using RoomWaiy.com, a platform operated by Privisa LLC. This document works together with our MemberDeals™ Terms & Conditions, Cancellations Policy, Refund Policy, Reporting Base Guidelines, Privacy Policy, and Cookies Policy

• EU Regulation 2016/679 (GDPR)
• California Consumer Privacy Act (CCPA)
• Montreal Convention on International Air Transport
• Applicable consumer and tourism codes
• Other national/international e-commerce and consumer protection laws
• Registration Number:xxxxxxxxxxx
• FSOT Number:xxxxxxxxxxxx
• TIDS Nomber:xxxxxxxxxxxx
• U.S. Tradmark Number:xxxxxxxxxxxxx