KUMBA AFRICA LLC
Last Updated: 01/01/2019
the same definition as in our Terms of Service.
When this policy mentions “Kumba,” “we,” “us,” “our,” or “the Data Controller” it refers to Kumba Africa, LLC,
There are three general categories of information we collect.
When you use the Kumba Platform and the Payment Services, we automatically collect information, including personal information, about the services you use and how you use them. This information is necessary or appropriate for the adequate performance of the contract between you and us (if any), to enable us to comply with legal obligations and to further our legitimate interest in being able to provide and improve the functionalities of the Kumba Platform and Payment Services.
Kumba may collect information (including personal information) that others provide about you when they use the Kumba Platform and the Payment Services, or obtain information from other sources and combine that with information we collect through the Kumba Platform and the Payment Services. We do not control or supervise how the third parties providing your information process your personal data, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.
We use, store, and process information, including personal information, about you to provide, understand, improve, and develop the Kumba Platform, create and maintain a trusted and safer environment and comply with our legal obligations.
We process this information given our legitimate interest in improving the Kumba Platform and our Members’ experience with it, and where it is necessary or appropriate for the adequate performance of the contract with you (if any).
We process this information given our legitimate interest in protecting the Kumba Platform, to measure the adequate performance of our contract with you (if any), and to comply with applicable laws.
We will process your personal information for the purposes listed in this section given our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest. You can opt-out of receiving marketing communications from us by following the unsubscribe instructions included in our marketing communications or changing your notification settings within your Kumba Account.
The Data Controller processes this information given its legitimate interest in improving the Payment Services and its users’ experience with it, and where it is necessary or appropriate for the adequate performance of the contract with you (if any) and to comply with applicable laws.
We don’t share your billing and payout or payment information with other Members, except the amount Travelers may owe to Hosts.
Based on our legitimate interest to promote the Kumba Platform, we may display parts of the Kumba Platform (e.g., your Listing page) on sites operated by Kumba’s business partners, using technologies such as widgets or APIs. If your Listings are displayed on a partner’s site, information from your public profile page may also be displayed. Information you share publicly on the Kumba Platform may be indexed through third party search engines. In some cases, you may be able to opt-out of this feature in your Account settings. If you change your settings or your public-facing content, these search engines may not update their databases. We do not control the practices of third party search engines, and they may use, store and/or make publicly available caches containing your outdated information.
Kumba may disclose your information, including personal information, to courts, law enforcement or
governmental authorities, or authorized third parties, if and to the extent we are required or permitted to
do so by law, or if such disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii)
to comply with legal process and to respond to claims asserted against Kumba, (iii) to respond to verified
requests relating to a criminal investigation or alleged or suspected illegal activity or any other
activity that may expose us, you, or any other of our users to legal liability, (iv) to enforce and
administer our Terms of Service, the Payments Terms or other agreements with Members, or (v) to protect the
rights, property or personal safety of Kumba, its employees, its Members, or members of the public.
These disclosures may also be necessary or appropriate to comply with our legal obligations, for the protection of your or another person's vital interests or for the purposes of our or a third party’s legitimate interest in keeping the Kumba Platform secure, preventing harm or crime, enforcing or defending legal rights, or preventing damage.
Where appropriate, we may notify Members about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon Kumba, Kumba’s property, its Members and the Kumba Platform. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that Member about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.
Kumba uses a variety of third party service providers to help us provide services related to the Kumba
Platform and the Payment Services. Where applicable, Kumba will need to share your information, including
personal information, in order to ensure the adequate performance of our contract with you (if any).
For example, service providers may help us: (i) verify your identity or authenticate your identification documents, (ii) check information against public databases, (iii) conduct background or police checks, fraud prevention, and risk assessment, (iv) perform product development, maintenance and debugging, (v) allow the provision of the Kumba Services through third party platforms and software tools, (vi) provide advertising, or (vii) provide payment services. These providers have limited access to your information to perform these tasks on our behalf.
Where permissible according to applicable law, we may use certain limited personal information about you,
such as your email address, to share it with social media platforms, to generate leads, drive traffic to
our websites or otherwise promote our products and services or the Kumba Platform. These processing
activities are based on our legitimate interest in undertaking marketing activities to offer you products
or services that may be of your interest.
The social media platforms with which we may share your personal data are not controlled or supervised by Kumba. Therefore, any questions regarding how your social media platform service provider processes your personal data should be directed to such provider.
Please note that you may at any time ask Kumba to cease processing your data for these direct marketing purposes by sending an e-mail to email@example.com.
In jurisdictions where Kumba facilitates or requires a registration, notification, permit, or license application of a Host with a local governmental authority through the Kumba Platform in accordance with local law, we may share information about participating Hosts with the relevant authorities, both during the application process and, if applicable, periodically thereafter. This information may include the Host’s full name and contact details, tax identification number, and Listing details.
We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.
We may review, scan, or analyze your communications on the Kumba Platform for fraud prevention, risk
assessment, regulatory compliance, investigation, product development, research, and customer support
purposes. In some cases, we may also scan, review, or analyze messages to debug, improve, and expand
product offerings. We use automated methods where reasonably possible. However, occasionally we may need to
manually review some communications, such as for fraud investigations and customer support, or to assess
and improve the functionality of these automated tools. We will not review, scan, or analyze your
communications to send third party marketing messages to you, and we will not sell reviews or analyses of
These activities are carried out based on Kumba's legitimate interest in ensuring compliance with applicable laws and our Terms, preventing fraud, promoting safety, and improving and ensuring the adequate performance of our services.
You may link your Kumba Account with your account at a third party social networking service. Your contacts on these third party services are referred to as “Friends.” When you create this link:
We only collect your information from linked third party accounts to the extent necessary or appropriate to ensure the adequate performance of our contract with you (if any), or to ensure that we comply with applicable laws, or with your consent.
The Kumba Platform may contain links to third party websites or services, such as third party integrations, co-branded services, or third party-branded services (“Third Party Partners”). Kumba does not own or control these Third Party Partners, and when you interact with them, you may be providing information directly to the Third Party Partner, Kumba, or both. These Third Party Partners will have their own rules about the collection, use, and disclosure of information. We encourage you to review the privacy policies of the other websites you visit.
You may exercise any of the rights described in this section by sending an email to firstname.lastname@example.org. Please note that we may ask you to verify your identity before taking any action on your request.
You may access and update some of your information by sending a request through the Contact Us section or through your Account settings. If you have chosen to connect your Kumba Account to a third-party application, like Facebook or Google, you can change your settings and remove permission for the app by changing your Account settings. You are responsible for keeping your personal information up-to-date.
You have the right to ask us to correct inaccurate or incomplete personal information concerning you (to the extent you cannot update such information yourself within your Kumba Account).
In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).
We generally retain your personal information for as long as is necessary for the performance of the contract between you and us (if any) and to comply with our legal obligations. If you no longer want us to use your information to provide the Kumba Platform to you, you can request that we erase your personal information and close your Kumba Account. Please note that if you request the erasure of your personal information:
Where you have provided your consent to the processing of your personal information by Kumba, you may withdraw your consent at any time by deleting your Account. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defense of legal claims; or (iv) you have objected to the processing pursuant to Section 6 (“Objection to Processing”) and pending the verification whether the legitimate grounds of Kumba override your own.
In some jurisdictions, applicable law may entitle you to require Kumba not to process your personal
information for certain specific purposes where such processing is based on legitimate interest. If you
object to such processing, Kumba will no longer process your personal information for these purposes unless
we can demonstrate compelling legitimate grounds for such processing or such processing is required for the
establishment, exercise or defense of legal claims.
Where your personal information is processed for direct marketing purposes, you may, at any time ask Kumba to cease processing your data for these direct marketing purposes by sending an e-mail to email@example.com.
EU Members have the right to lodge complaints about the data processing activities carried out by Kumba before the competent data protection authorities.
Some of the safeguards we use to protect your information include, for example, firewalls and encryption password protection, and information access controls. If you know or have reason to believe that your Kumba Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your Kumba Account, please contact us immediately following the instructions in the Contact Us section of the Site.
Kumba Africa LLC
3230 Market Street
Pearlstein Building 4th Floor
Philadelphia, Pennsylvania 19104