Introduction

THE NEST respects your privacy and is committed to protecting Data. This Privacy Policy will inform you as to how we look after Data when you visit and use our Platform (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Glossary

You OR Your: shall refer to the users of our Platform.

Platform: It means THE NEST Platform whereby its Services shall be used.

Data: the information that we collect from users while using the Platform.

Services It means THE NEST services and described by the Terms and Conditions.

Account: It refers to the User account on the Platform.

THE NEST: It refers to the platform owned by Nestologia Hub under commercial registration number 251516 Cairo Investment office Subject to the provisions of Law No. 72 of 2017

Important information and who we are

Purpose of this Privacy Policy:

This Privacy Policy aims to give you information on how THE NEST collects and processes Data through your use of our Platform, including any Data you may provide through this Platform when you register and/or use our Services, as well as sign up to our Platform.

It is important that you read this Privacy Policy along with our Terms and Conditions when we are collecting or processing Data about you so that you are fully aware of how and why we are using this Data. This Privacy Policy supplements other notices and Privacy Policies and is not intended to override them.

Controller

Nestologia Hub under commercial registration number 251516 Cairo Investment office Subject to the provisions of Law No. 72 of 2017 is the controller and responsible for Data (referred to as “THE NEST“, “we”, “us” or “our” in this Privacy Policy). NESTOLOGIA HUB is the controller and responsible for this Platform.   

Contact details

If you have any questions about this Privacy Policy or our privacy practices, please feel free to contact us via the email address:

E-mail address: wecare@tnehospitality.com

Changes to the Privacy Policy and your duty to inform us of changes

We keep our Privacy Policy under regular review.

It is important that the Data we hold about you is accurate and current. Please keep us informed if Data changes during your relationship with us.

Third-party Links

This Platform may include links to third-party Platform s and plug-ins. Clicking on those links or enabling those connections may allow third parties to collect or share Data about you. We do not control these third-party Platform s and we are not responsible for their privacy statements. We recommend you read the Privacy Policy of every Platform you visit.

Data that we collect

Data means any information about an individual or institution from which that entity can be identified. It does not include Data where the identity has been removed (anonymous Data).

We may collect, use, store and transfer different kinds of Data about you, which is included, but not limited to the following:

–    Identity Data includes first name, middle name, username or similar identifier, date of birth and gender.

–    Where appropriate, we may ask you for an image of your government-issued ID document(s), passport, national ID card, tax ID, or driving license (in accordance with applicable laws) or other verification information, such as your date of birth, address, email address, phone number, or digital identity, and/or a selfie when we verify your ID. If a copy of your ID is provided to us, we will obtain information from your ID.

–    Contact Data includes phone number, e-mail and postal addresses.

–    Financial Data includes your bank account information, credit card details, cardholder name, expiration date, authentication code and billing address.

–    Technological Data includes your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and location, and other technology on the devices you use to access the Platform.

–    Profile Data includes your username and password, your interests, preferences, purchasing power, reviews and ratings, feedback, and survey responses.

–    Usage Data includes information about how you use our Platform and your transaction history.

–    Photos, reviews, social posts, and videos you may have provided to us.

–    Geolocation Data.

–    Insurance Information, when you express interest in purchasing a Travel Insurance Plan, Reservation Insurance, or Stay Protection (“Insurance”), we may collect certain information required prior to completing the insurance agreement. This pre-contract information may include: your full name, accommodation address, residential address, date of birth, age, email address, contact number, trip start and end dates, trip cost, transaction currency, and booking reference number. This data is necessary to process your insurance request and ensure appropriate coverage is offered.

–    Information About Others, Such as a payment instrument or contact information belonging to another person or information about a co-traveler. By providing us with personal information about others, you certify that you have permission to provide that information to The Nest for the purposes described in this Privacy Policy and you have shared The Nest Privacy Policy with them.

–    The company incorporation documents which including but not limited to (Articles of Association, Commercial Register, Tax Card and investment gazette.) 

In addition to the categories noted above, we may also collect certain location Data if you have instructed your device to send such Data via the privacy settings on that device.

We also collect, use, and share aggregated Data such as statistical or demographic Data for any purpose. Aggregated Data could be derived from Data but is not considered Data in law as this Data will not directly or indirectly reveal your identity. For example, we may aggregate your usage Data to calculate the percentage of users accessing a specific Platform feature. However, if we combine or connect aggregated Data with Data so that it can directly or indirectly identify you, we treat the combined Data as Data which will be used in accordance with this Privacy Policy.

We do not collect any special categories of Data (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership). Nor do we collect any information about criminal convictions and offences.

At THE NEST, we use the data we collect to develop and train AI models to improve our services, including but not limited to: content personalization, improving the performance of our services. We emphasize that we are committed to protecting your privacy, we do not disclose sensitive information, and we ensure the security of your data through robust security technologies.

If you fail to provide Data

Where we need to collect Data by law, by using our Platform, and you fail to provide the required Data, we may not be able to perform our Services. We will notify you if this is the case at the time.

How is Data collected?

We use different methods to collect Data from and about you including through:

Direct interactions. You may give us your Identity, contact and financial Data by filling in forms or by corresponding with us by phone or e-mail or otherwise. This includes Data you provide when you undertake the following:

–    Create an Account on, or exploit, our Platform;

–    Enter a social competition, promotion, or survey; or

–    Provide us with feedback or contact us.

Automated technologies or interactions. As you interact with our Platform, we will automatically collect technical data about your browsing actions and patterns. We collect this Data by using cookies, server logs and other similar technologies.

Information we collect from third parties, we may collect personal information from other sources, such as:

Third-Party Applications If you choose to link, connect, or log in to The Nest using a third-party service—such as Google and Facebook,—you authorize that service to share certain information with us. This may include your name, email address, profile photo, friends list, or other data as controlled by that service’s privacy settings or your permissions.

If you choose to connect a smart device, such as a smart lock, to your account, we may collect related information such as device logs, usage events, and technical specifications necessary for service functionality.

Enterprise Product Invitations and Account Management, Organizations using our enterprise products may provide personal information to help manage user accounts, assign roles, and send invitations to access enterprise features on The Nest.

Referrals and Co-Travelers, if you are invited to use The Nest—for example, as a co-traveler—the individual inviting you may submit personal information about you, such as your name and contact details.

Complainants, if a Host, Guest, or third party submits a complaint about you, we may collect, and process information related to that complaint in order to review and respond appropriately.

Financial Institutions, if you choose to pay using a bank account, we may receive certain information from your financial institution, including account details and available balance, to complete the transaction.

Flexible Payment Plans and Financing Providers, if you use an installment payment option, we may receive relevant data from third-party financing providers, including your approved payment plan, payment schedule, and transaction history.

How we use Data

To the extent possible, we want to provide you with relevant content and a tailored experience when you use our Services, and we use Data about you to do that.

We will only use Data when the law allows us to. Most commonly, we will use Data in the following circumstances:

–    Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;

–    Where we need to comply with a legal obligation;

–    Where we need to set up your Account and administrate it;

–    Where we need to carry out surveys;

–    Where we need to personalize content, user experience or business information;

–    Where you have given consent.

–    Generally, we do not rely on consent as a legal basis for processing Data although we will get your consent before sending third party direct marketing communications to you via e-mail or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use Data

1.  Performance of our Services:

We process Data because it is necessary for the performance of our Services through our Platform.

In this respect, we use Data for the following:

–    To prepare a proposal for you regarding the Services we offer;

–    To provide you with the Services as set in the scope of our Services, or as otherwise agreed with you from time to time;

–    To deal with any complaints or feedback you may have;

–    For any other purpose for which you provide us with the Data which we collect

–    In this respect, we may share Data with or transfer it to the following:

–    Subject to your consent, independent third parties whom we engage with to assist in delivering the Services to you;

–    Our Professional Advisers where it is necessary for us to obtain their advice or assistance, including lawyers, accountants, IT or public relations advisers;

–     Our Data storage providers.

–    the European General Data Protection Regulation (GDPR) and the Egyptian law no. 151 for year 2020. Due to the said purposes, to guarantee security and a smooth connection setup, we have a legitimate interest to process this Data.

2. Legitimate interests:

We also process Data because it is necessary for our legitimate interests, or sometimes where it is necessary for the legitimate interests of a third party.

In this respect, we use Data for the administration and management of our business, marketing purposes, archiving or statistical analysis.

3.  Legal Compliance:

We also process Data for our compliance with a legal obligation which we are under. In this respect, we will use Data for the following:

–    Resolve disputes or troubleshoot problems;

–    Prevent fraud and other potentially prohibited or unlawful activities;

–    Comply with relevant laws, respond to legal requests, prevent harm, and protect our rights and the rights of other users and third parties;

–    As required by tax authorities or any competent court or legal authority.

4. Marketing:

We will send you marketing about Services we provide which may be of interest to you, as well as other information in the form of alerts, newsletters, notifications for discounts and deals, or functions which we believe might be of interest to you or in order to update you with information which we believe may be relevant to you. We will communicate this to you in a number of ways including by telephone, SMS, e-mail or other digital channels as appropriate.

5. Communication:

Communicate with you or facilitate communication between you, our affiliates;

Host your reviews, ratings, photos, videos, and other content;

Customize your experience, including customizing the ads shown to you on and off our Platform;

Respond to your questions and comments.

6. Promotional offers from us:

We may use Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which Services, discounts and deals may be relevant to you.

You will receive marketing communications from us in case of using our Platform, and you have not opted out of receiving these marketing communications.

7. Third-party marketing:

We will get your express opt-in consent before we share Data with any third party for marketing purposes or for R&D.

You can ask us or third parties to stop sending you marketing messages at any time by logging into the Platform and checking or unchecking relevant boxes to adjust your marketing preferences, or by following the opt-out links on any marketing message sent to you or by contacting us at any time

8. Cookies:

You can set your browser to refuse all or some browser cookies, or to alert you when the Platform sets or access cookies. If you disable or refuse cookies, please note that some parts of this Platform may become inaccessible or not function properly.

9. Change of purpose:

We will only use Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contacts us on the e-mail address wecare@tnehospitality.com If we need to use Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law

Disclosures of Data

We may share Data with the parties set out herein in relation to the specified purposes for which we will use the Data above.

we may disclose your information, where legally required or reasonably necessary, to:

·       Courts, law enforcement, tax agencies, public authorities, or other Members

·       Respond to legal obligations (e.g. subpoenas, court orders, investigations)

·       Prevent fraud, address illegal activity, or reduce risk of legal exposure

·       Enforce our Terms, investigate violations, or respond to emergencies

·       Protect the safety, rights, or property of The Nest, its users, employees, or the public

To Tax Authorities, If required by law, we may share information about Hosts and Guests with relevant tax authorities to support proper tax compliance.

To Governmental Authorities for Registrations, in jurisdictions where registration, notification, permits, or license numbers are needed, we may share Host data—such as registration details and contact information—with authorities during the registration process or afterward.

Why we may share information

Build Your Public Profile, some information you choose to share on The Nest platform may become publicly visible and searchable via third-party search engines. You may be able to limit this to your account settings. Examples of public information include:

·       Your profile and account details (such as name, photo, description, etc.)

·       Listing pages with information about the accommodation or experience (e.g. location, calendar availability, host photo, and optional details)

·       Reviews, ratings, and feedback

·       Posts or content you share on community forums, blogs, or social media

·       Listing information shared on third-party platforms, websites, or apps

Data security

We have put in place appropriate security measures to prevent Data from being accidentally lost, used, or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to Data to those employees, contractors, third party service providers and other parties who have a valid need to know. They will only process Data in accordance with our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

How long will we use Data?

We will only retain Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, or reporting requirements. We may retain Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with You.

To determine the appropriate retention period for Data, we consider the amount, nature and sensitivity of the Data, the potential risk of harm from unauthorized use or disclosure of Data, the purposes for which we process Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, or other requirements

When it is no longer necessary to retain Data, we will delete it

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access Data (or to exercise any of your other rights). This is a security measure to ensure that Data is not disclosed to any person who has no right to receive it.

We may also contact you to ask you for further information to improve our Services.

How do we deal with the “right to be forgotten”?

You have the right to request the erasure of Data that we hold about you in certain circumstances, for example if it were not acquired for, or has ceased to be necessary for, a lawful purpose. This is known as the right to be forgotten. Where you request that we erase your Data, we will usually only do so when the Data has ceased to be publicly available or where we no longer use it.

Lawful Basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best Service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process Data or for our legitimate interests. We do not use Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Comply with a legal obligation means processing Data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

Professional advisers acting as processors or joint controllers including lawyers, bankers, and auditors, who provide consultancy, banking, legal and accounting services.

YOUR LEGAL RIGHTS

You have the right to:

Access to Data on our Platform. This enables you to receive a copy of Data we hold about you and to check that we are lawfully processing it.

Request correction of the Data that we hold about you. This enables you to have any incomplete or inaccurate Data we hold about you corrected, though we may need to verify the accuracy of the new Data you provide to us.

Request erasure of personal Data. This enables you to ask us to delete or remove Data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase Data to comply with local law.

Object to processing of Data where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object to where we are processing Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.