Privacy Policy

Thank you for using Balto! This Privacy Policy describes how we collect, use, process, and disclose your information, including personal information, in conjunction with your access to and use of the Balto Platform and the Payment Services. When this policy mentions "Balto," "we," "us," or "our," it refers to the Balto company that is responsible for your information under this Privacy Policy (the "Data Controller").

1. INFORMATION WE COLLECT There are three general categories of information we collect.

1.1 Information You Give to Us. 1.1.1 Information that is necessary for the use of the Balto Platform. We ask for and collect the following personal information about you when you use the Balto Platform. This information is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all the requested services. Account Information. When you sign up for a Balto Account, we require certain information such as your first name, last name, email address, and date of birth. Identity Verification Information. To help create and maintain a trusted environment, we may collect identity verification information (such as images of your government issued ID, passport, national ID card, or driving license, as permitted by applicable laws) or other authentication information. Payment Information. To cash out winnings, we may require you to provide certain financial information (like your bank account or credit card information) in order to facilitate the processing of payments (via Balto Payments). Communications with Balto and other Members. When you communicate with Balto or use the Balto Platform to communicate with other Members, we collect information about your communication and any information you choose to provide.

1.1.2 Information you choose to give us. You may choose to provide us with additional personal information in order to obtain a better user experience when using Balto Platform. This additional information will be processed based on your consent. Additional Profile Information. You may choose to provide additional information as part of your Balto profile (such as gender, preferred language(s), city, and a personal description). Some of this information as indicated in your Account settings is part of your public profile page, and will be publicly visible to others. Other Information. You may otherwise choose to provide us information when you fill in a form, conduct a search, update or add information to your Balto Account, respond to surveys, post to community forums, participate in promotions, or use other features of the Balto Platform.

1.1.3 Information that is necessary for the use of the Payment Services. The Payments Data Controller needs to collect the following information, as it is necessary for the adequate performance of the contract with you and to comply with applicable law (such as anti-money laundering regulations). Without it, you will not be able to use Payment Services: Payment Information. When you use the Payment Services, the Payments Data Controller requires certain financial information (like your bank account or credit card information) in order to process payments and comply with applicable law.

1.2 Information We Automatically Collect from Your Use of the Balto Platform and Payment Services. When you use the Balto 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 for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of the Balto Platform and Payment Services. Geo-location Information. When you use certain features of the Balto Platform, we may collect information about your precise or approximate location as determined through data such as your IP address or mobile device's GPS to offer you an improved user experience. Most mobile devices allow you to control or disable the use of location services for applications in the device's settings menu. Balto may also collect this information even when you are not using the app if this connection is enabled through your settings or device permissions. Usage Information. We collect information about your interactions with the Balto Platform such as the pages or content you view, your searches for Listings, bookings you have made, and other actions on the Balto Platform. Log Data and Device Information. We automatically collect log data and device information when you access and use the Balto Platform, even if you have not created a Balto Account or logged in. That information includes, among other things: details about how you've used the Balto Platform (including if you clicked on links to third party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you've viewed or engaged with before or after using the Balto Platform. Cookies and Similar Technologies. We use cookies and other similar technologies, such as web beacons, pixels, and mobile identifiers. We may also allow our business partners to use these tracking technologies on the Balto Platform, or engage others to track your behavior on our behalf. While you may disable the usage of cookies through your browser settings, the Balto Platform currently does not respond to a "Do Not Track" signal in the HTTP header from your browser or mobile application due to lack of standardization regarding how that signal should be interpreted. Payment Transaction Information. Balto Payments collects information related to your payment transactions through the Balto Platform, including the payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, IBAN information, your address and other related transaction details. This information is necessary for the adequate performance of the contract between you and Balto Payments and to allow the provision of the Payment Services.

2. HOW WE USE INFORMATION WE COLLECT We use, store, and process information, including personal information, about you to provide, understand, improve, and develop the Balto Platform, create and maintain a trusted and safer environment and comply with our legal obligations.

2.1 Provide, Improve, and Develop the Balto Platform. Enable you to access and use the Balto Platform. Enable you to communicate with other Members. Operate, protect, improve, and optimize the Balto Platform and experience, such as by performing analytics and conducting research. Provide customer service. Send you service or support messages, updates, security alerts, and account notifications. If you provide us with your contacts' information, we may process this information: (i) to facilitate your referral invitations, (ii) send your requests for references, (iii) for fraud detection and prevention, and (iv) for any purpose you authorize at the time of collection. To operate, protect, improve, and optimize the Balto Platform and experience, and personalize and customize your experience (such as making Listing suggestions or ranking search results), we conduct profiling based on your interactions with the Balto Platform, your search and booking history, your profile information and preferences, and other content you submit to the Balto Platform. We process this information given our legitimate interest in improving the Balto Platform and our Members' experience with it, and where it is necessary for the adequate performance of the contract with you.

2.2 Create and Maintain a Trusted and Safer Environment. Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity. Conduct security investigations and risk assessments. Verify or authenticate information or identifications provided by you (such as to verify your Accommodation address or compare your identification photo to another photo you provide). Conduct checks against databases and other information sources, including background or police checks, to the extent permitted by applicable laws and with your consent where required. Comply with our legal obligations. Resolve any disputes with any of our Members and enforce our agreements with third parties. Enforce our Terms of Service and other policies. In connection with the activities above, we may conduct profiling based on your interactions with the Balto Platform, your profile information and other content you submit to the Balto Platform, and information obtained from third parties. In limited cases, automated processes may restrict or suspend access to the Balto Platform if such processes detect a Member or activity that we think poses a safety or other risk to the Balto Platform, other Members, or third parties. We process this information given our legitimate interest in protecting the Balto Platform, to measure the adequate performance of our contract with you, and to comply with applicable laws.

2.3 Provide, Personalize, Measure, and Improve our Advertising and Marketing. Send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences (including information about Balto or partner campaigns and services) and social media advertising through social media platforms such as Facebook or Google). Personalize, measure, and improve our advertising. Administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Balto or its third party partners. Conduct profiling on your characteristics and preferences (based on the information you provide to us, your interactions with the Balto Platform, information obtained from third parties, and your search and booking history) to send you promotional messages, marketing, advertising and other information that we think may be of interest to you. 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 Balto Account. 2.4 How the Payments Data Controller uses the Information Collected. Enable you to access and use the Payment Services. Detect and prevent fraud, abuse, security incidents, and other harmful activity. Conduct security investigations and risk assessments. Conduct checks against databases and other information sources. Comply with legal obligations (such as anti-money laundering regulations). Enforce the Payment Terms and other payment policies. With your consent, send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences. The Payments 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 for the adequate performance of the contract with you and to comply with applicable laws.

3. SHARING & DISCLOSURE 3.1 With Your Consent. Where you have provided consent, we share your information, including personal information, as described at the time of consent, such as when you authorize a third party application or website to access your Balto Account or when you participate in promotional activities conducted by Balto partners or third parties.

3.2 Compliance with Law, Responding to Legal Requests, Preventing Harm and Protection of our Rights. Balto and Balto Payments 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 Balto, (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 Payment Terms or other agreements with Members, or (v) to protect the rights, property or personal safety of Balto, its employees, its Members, or members of the public. These disclosures may be necessary 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 Balto 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 Balto's property, its Members and the Balto 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.

3.3 Service Providers. Balto uses a variety of third party service providers to help us provide services related to the Balto Platform and the Payment Services. 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 Balto Services through third party platforms and software tools (e.g. through the integration with our APIs), or (vi) provide customer service, advertising, or payments services. These providers have limited access to your information to perform these tasks on our behalf, and are contractually bound to protect and to use it only for the purposes for which it was disclosed and consistent with this Privacy Policy. Balto will need to share your information, including personal information, in order to ensure the adequate performance of our contract with you.

3.4 Corporate Affiliates. To enable or support us in providing the Balto Platform and the Payment Services, we may share your information, including personal information, within our corporate family of companies (both financial and non-financial entities) that are related by common ownership or control. Sharing with Balto, Inc. Even if your Country of Residence is not the United States, your information may be shared with Balto which provides the technical infrastructure for the Balto Platform, product development and maintenance, customer support, trust and safety and other business operation services to other Balto entities. The data sharing is necessary for the performance of the contract between you and us and is based on our legitimate interests in providing the Balto Platform globally. Sharing with Balto Payments. In order to facilitate payments on or through the Balto Platform, certain information as described above in Section 1.1.3, may be shared with the relevant Balto Payments entity. The data sharing is necessary for the performance of the contract between you and us.

3.5 Social Media Platforms. Where permissible according to applicable law we may use certain limited personal information about you, such as your email address, to hash it and to share it with social media platforms, such as Facebook or Google, to generate leads, drive traffic to our websites or otherwise promote our products and services or the Balto Platform. These processing activities are based on our legitimate interest in undertaking marketing activities to offer you products or services that may be if your interest. The social media platforms with which we may share your personal data are not controlled or supervised by Balto. 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 Balto to cease processing your data for these direct marketing purposes by sending an e-mail to support@baltopools.com.

3.6 Aggregated Data. 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.

4. OTHER IMPORTANT INFORMATION

4.1 Analyzing your Communications. We may review, scan, or analyze your communications on the Balto Platform for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, and customer support purposes. For example, as part of our fraud prevention efforts, we scan and analyze messages to mask contact information and references to other websites. 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 communications. These activities are carried out based on Balto'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.

5. THIRD PARTY PARTNERS & INTEGRATIONS The Balto 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"). Balto doesn't own or control these Third Party Partners and when you interact with them, you may be providing information directly to the Third Party Partner, Balto, 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.

6. YOUR RIGHTS You may exercise any of the rights described in this section before your applicable Balto Data Controller and Payments Data Controller by sending an email to support@baltopools.com. Please note that we may ask you to verify your identity before taking further action on your request.

6.1 Managing Your Information. You may access and update some of your information through your Account settings. If you have chosen to connect your Balto 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.

6.2 Rectification of Inaccurate or Incomplete Information. You have the right to ask us to correct inaccurate or incomplete personal information concerning you (and which you cannot update yourself within your Balto Account).

6.3 Data Access and Portability. 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).

6.4 Data Retention and Erasure. We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you no longer want us to use your information to provide the Balto Platform to you, you can request that we erase your personal information and close your Balto Account. Please note that if you request the erasure of your personal information: We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend an Balto Account for fraud or safety reasons, we may retain certain information from that Balto Account to prevent that Member from opening a new Balto Account in the future. We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, Balto may keep some of your information for tax, legal reporting and auditing obligations. Information you have shared with others (e.g., Reviews, forum postings) may continue to be publicly visible on the Balto Platform, even after your Balto Account is cancelled. However, attribution of such information to you will be removed. Additionally, some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers. Because we maintain the Balto Platform to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.

6.5 Withdrawing Consent and Restriction of Processing. Where you have provided your consent to the processing of your personal information by Balto you may withdraw your consent at any time by changing your Account settings or by sending a communication to Balto specifying which consent you are withdrawing. 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 defence of legal claims; or (iv) you have objected to the processing pursuant to Section 6.6 and pending the verification whether the legitimate grounds of Balto override your own.

6.6 Objection to Processing. In some jurisdictions, applicable law may entitle you to require Balto not to process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing Balto 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 defence of legal claims. Where your personal information is processed for direct marketing purposes, you may, at any time ask Balto to cease processing your data for these direct marketing purposes by sending an e-mail to support@baltopools.com.

6.7 Lodging Complaints. You have the right to lodge complaints about the data processing activities carried out by Balto before the competent data protection authorities.

7. SECURITY We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls. If you know or have reason to believe that your Balto Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your Balto Account, please contact us following the instructions in the Contact Us section below.

8. CHANGES TO THIS PRIVACY POLICY Balto reserves the right to modify this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on the Balto Platform and update the "Last Updated" date at the top of this Privacy Policy. We will also provide you with notice of the modification by email at least thirty (30) days before the date they become effective. If you disagree with the revised Privacy Policy, you may cancel your Account. If you do not cancel your Account before the date the revised Privacy Policy becomes effective, your continued access to or use of the Balto Platform will be subject to the revised Privacy Policy.

9. CONTACT US If you have any questions or complaints about this Privacy Policy or Balto's information handling practices, you may email us or contact us at support@baltopools.com