Last Revised: April, 2014

Roomer Travel Ltd. and its affiliates ("Roomer", "we" or "us") respect your privacy and are committed to protect the personal information they share with us. In connection with the use of our site and/or Services (as such terms are defined in our terms of use). This Privacy Policy (the "Private Policy") is intended to describe our practices regarding the information we may collect from you ("User" or "you") when you use our Site and/or Service, the manners in which we may use such information, and the options and rights available to you. Capitalized terms which are not defined herein, shall have the meaning ascribed to them in the Terms of use, (the "Terms") which this Privacy Policy is incorporated there to by reference.

BY ACCESSING AND/OR USING THE SITE AND/OR SERVICE, YOU AGREE TO THE TERMS AND CONDITIONS SET FORTH IN THIS PRIVACY POLICY, INCLUDING TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION (AS DEFINED BELOW). IF YOU DISAGREE TO ANY TERM PROVIDED HEREIN, YOU MAY NOT USE THE SITE AND/OR THE SERVICE.

We may collect two types of data and information from our Users:

1. The first type of information is un-identified and non-identifiable information pertaining to a User(s), which may be made available or gathered via the User's use of the site and/or Service ("Non-personal Information"). We are not aware of the identity of the User from which the Non-personal Information was collected. Non-Personal Information which is being collected consists of technical and/or behavioral information, including the User's device screen size and display settings, User's last login, etc, and including aggregated information and data produced, deducted and/or inferred by us, such as statistics regarding Site and/or Service performance and Users' usage patterns.
2. The second type of information is individually identifiable information namely information that identifies an individual or may with reasonable effort identify an individual or may be of private or sensitive nature. ("Personal Information").

Personal Information which is being gathered consists of the User's IP address or other persistent user identifier, and any personal details provided voluntarily by the User. Which may include, without limitation, identification and contact details such as first and last name, phone number and e-mail address and additional Personal Information needed for the purpose of verifying Sellers and Buyers identity, authenticating Reservations and processing payments. Which may include, without limitation, credit card details, bank account details and PayPal account information.

1. We collect Non-Personal Information through your use of the Site and/or Service. In other words, when you are using the Site and/or Service we may gather, collect and record the information relating to such usage either ourselves or through the services of a third party (as further detailed in Section 9 below).
2. We collect Personal Information which you provide to us in different stages of using the Service:
   1. Use of the site: when you access and use the Site, you automatically provide us with your IP address and/or other persistent user identifier.
   2. Signup stage: when you register to our Service we collect Personal Information which will be hosted on your personal Profile (including your name, mail address, phone number etc.). Registration can be done either by completing the registration form, where you will be asked to provide us with the Personal Information aforementioned, or via your Facebook account ("Facebook Connect"). By using Facebook Connect in order to register to the Service, you permit Facebook to provide Roomer and permit Roomer to use the aforementioned Personal Information retained within your Facebook account. You may also permit Facebook to provide to Roomer and permit Roomer to use additional Personal Information retained within your Facebook account, which may not be mandatory for the purpose of registration to the Service, such as your friends list, image, place of residence.
   3. Buying Reservations: Buyers may use their PayPal account or their credit card in order to purchase Reservations on the Service. According to the preferred method of payment, the Buyer will be asked to provide us with the relevant Personal Information (PayPal account details or credit card and additional billing details). We will not store these details but only use them to collect the payment from you.
   4. Cash-out after selling Reservations: Sellers may choose a preferred method of payment in order to receive payment they are entitled to, for the Reservation they sold on the Service. According to the preferred method of payment, the Seller will be asked to provide us with the relevant Personal Information (PayPal account details or bank account details). We will not store these details but only use them to process the payment for you

Non-personal Information is collected in order to:

• Use it for statistical and research purposes and for customization and improvement of the user experience on the Service and/or Site.

Personal Information is collected in order to:

• Allow Sellers and Buyers to sell, buy Reservations.
• Provide Sellers with payments owed to them, and allow Buyers to pay for Reservations.
• Operate on behalf of the Seller in connection with the Reservations.
• Allow us to provide registered Users with information related to transactions they made on the Service (receive email notifications regarding the posting of a Reservation on the Site, the sale of a Reservation, eligibility for Payment, etc.).
• Verify the identities of Sellers and Buyers and prevent fraud attempts.
• Allow us to contact registered Users in order to receive their feedback for using the Service.
• Provide User support, as applicable.
• Use it in the aggregate for statistical and research purposes.

Notwithstanding the above aforementioned, Roomer may also disclose Personal Information in the following cases: (a) to satisfy any applicable law, regulation, legal process, subpoena or governmental request; (b) to enforce this Privacy Policy and/or the Terms, including investigation of potential violations thereof; (c) to detect, prevent, or otherwise address fraud, security or technical issues; (d) to respond to User's support requests; (e) to respond to claims that any content available on the Site violates the rights of third-parties; (f) to respond to claims that contact information (e.g. name, e-mail address, etc.) of a third-party had been posted or transmitted without their consent or as a form of harassment; (g) to protect the rights, property, or personal safety of Roomer, its Users, or the general public; (h) when Roomer is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of its assets; (i) to collect, hold and manage your Personal Information through a third party's cloud based services, as reasonable for business purposes, which may be located in countries outside of your jurisdiction, including but not limited to the United States of America; or (j) to allow the Buyer of your Reservation to use such Reservation; (k)pursuant to your explicit approval prior to the disclosure. For avoidance of doubt, Roomer may transfer and disclose Non-personal Information to third parties at its own discretion.

You may view and change Personal Information hosted on your Profile and profile image at any time, or simply remove your Profile and all Personal Information incorporated therein at any time for any reason through the Site or by contacting Roomer at: https://www.roomertravel.com/support/contact with such specific request. Your Profile will be terminated within reasonable time following your request, and from that date of termination you will no longer be able to access your Profile

Direct Marketing: You hereby agree that we may use your contact details for the purpose of informing you regarding products and services (offered by the Company and/or by third parties) which may interest you and to send to you advertisements and other marketing material, transmitted to the e-mail address you have provided to us upon registration to the Site. You may withdraw your consent via sending a written notice to the Company by email to the following address: help@roomertravel.com. It is clarified that we are not responsible for the content of said advertisements and the products delivered or services rendered thereby by third parties and you irrevocably and unconditionally agree that we shall not be held responsible or liable in connection thereof.

Advertisements: We accept advertisements from third party advertisers. These advertisers are carefully selected to provide information about products and services that we think may be of interest to our Users. Note that if you click on any of these advertisements, these advertisers may use cookies and other web-tracking technologies to collect non-personal and/or personal information about you. We recommend that you review the terms of use and privacy policy for any advertiser with which you are interacting before doing so. Their privacy policy, not ours, will apply to any of those interactions.

We take a great care in implementing and maintaining the security of our Service and Site and of our Users' Personal Information. Roomer employs industry standard procedures and policies to ensure the safety of its Users’ Personal Information, and prevent unauthorized use of any such information, including encrypting information using secure socket layer technology (SSL). We follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. However, we do not guarantee that unauthorized access will never occur.

While using the Site we may be using third party software and/or service, in order to collect and/or process the information detailed herein. Such software includes without limitation, "KISSmetrics", which privacy policy is available at https://www.kissmetrics.com/; "Mouseflow" which privacy policy is available at: http://www.mouseflow.com/privacy/ ; and Google Analytics, which privacy policy is available at http://www.google.com/intl/en/analytics/privacyoverview.html.

When you access or use the Service, Company may use industry-wide technologies such as "cookies" and Flash (or similar technologies), which stores certain information on your computer ("Local Storage") and which will allow us to enable automatic activation of certain features, and make your Service experience much more convenient and effortless. The cookies used by the Service are created per session, does not include any information about you, other than your session key and are removed as your session ends (usually after 24 hours). It is easy to prohibit the Local Storage. Most browsers will allow you to erase cookies from your computer's hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. In order to erase or disable the Local Storage option in Flash you should use the settings option of Flash according to the specific instructions provided by the technology provider. However, if you block or erase cookies, or change the settings of Flash, your online experience may be limited.

The terms of this Privacy Policy will govern the use of the Service and/or Site and any information collected therein. Roomer reserves the right to change this policy at any time, so please re-visit this page frequently. We will notify you regarding substantial changes of this policy on the homepage of the Site and/or we will send you an e-mail regarding such changes to the e-mail address that you provided in the registration form. Changes to this Privacy Policy are effective as of the stated "Last Revised" date and your continued use of the Site and/or Service after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes.

If you have any questions (or comments) concerning the Terms or this Privacy Policy, you are most welcomed to contact us at https://www.roomertravel.com/support/contact or simply call us at: +1(415)376-1455. Roomer will make an effort to reply within a reasonable timeframe.