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demoDemo: every listing is an example, and a request to a host goes nowhere and is kept nowhere. Launch — fill in: pilot launch date.

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Documents

Data passed to host and guest

DraftDraft, not in force. Operator: fill in: operator’s legal entity; a lawyer reviews the text before launch. In the demo the site collects nothing: requests go nowhere and are stored nowhere. This is a translation; the Russian text is the legally binding one.

The host and the guest see exactly as much about each other as each step needs. Contacts and the exact address — only after the request is confirmed. This document sets out what exactly is passed, when and on what grounds, and what changes when the home is outside Russia.

Contents

1.Before confirmation

  1. 1.1

    The host sees the request: the guest’s name, the “Absolute member” mark, dates, number of guests — how many adults, children and pets — the request text, arrival time and reviews of the guest.

  2. 1.2

    The guest sees the listing: the district, not the house. The host’s phone number is hidden.

  3. 1.3

    Phone numbers, links and card numbers in the request text are hidden.

2.After confirmation

  1. 2.1

    To the guest — the exact address: street, building, entrance, floor, flat, how to find the door. The address is handed out by a database function, only to this guest and only from confirmation to the day after departure.

  2. 2.2

    To the guest — the host’s phone number and the photos marked “after confirmation”.

  3. 2.3

    To the host — the guest’s phone number.

  4. 2.4

    Every opening of the address is written to a log. The host can see who opens the address and when.

  5. 2.5

    Cancelling the stay closes access to the address.

3.Legal grounds

  1. 3.1

    Phone numbers and the address are passed to perform the agreement with the user, that is, the platform rules (Federal Law 152-FZ on personal data, art. 6 part 1 cl. 5), and under the consent to personal data processing, which names this transfer.

4.What is not passed

  1. 4.1

    Passport details: for registration the host takes the document from the guest personally at check-in.

  2. 4.2

    Key box and lock codes: the host passes them personally on the day of arrival; the platform does not store them.

  3. 4.3

    Private notes to the team and check results — apart from the marks on the profile.

5.What the recipient does

  1. 5.1

    The other party’s data are for this stay only: to get in touch, meet, check in, register the guest. They may not be published, passed to others or used for mailings.

  2. 5.2

    The recipient keeps the other party’s phone number no longer than the stay and any dispute need. On the site, the other party’s number stops showing fill in: period after departure.

  3. 5.3

    A host who receives a guest’s passport details for registration keeps them safe and deletes them after departure. Whether the host is then a personal data operator: fill in: lawyer’s answer.

6.Homes outside Russia: Phu Quoc

  1. 6.1

    Data of Russian citizens are recorded and stored in a database in Russia, wherever the home is (152-FZ art. 18 part 5).

  2. 6.2

    Passing a guest’s name and phone number to a host in Vietnam who is a Russian citizen is probably not a cross-border transfer: a cross-border transfer is a transfer to the territory of a foreign state, to a foreign authority, a foreign individual or a foreign legal entity (152-FZ art. 3 cl. 11). Classification: fill in: lawyer’s answer.

  3. 6.3

    If the transfer is cross-border, the operator notifies Roskomnadzor before it starts and, before notifying, obtains the required information from the host (152-FZ art. 12 parts 3, 5). Vietnam is on the list of countries with adequate protection of the rights of personal data subjects (Roskomnadzor order No. 128 of 05.08.2022), so after the notification the transfer may start at once (art. 12 part 10 as amended by 265-FZ of 26.07.2026).

  4. 6.4

    Until a Vietnamese lawyer answers, hosts on Phu Quoc are Russian citizens only, and the data stay in the database in Russia.

  5. 6.5

    Hosts who are Vietnamese citizens join after a Vietnamese lawyer answers: under Law 91/2025/QH15, processing data collected in Vietnam on a platform abroad is also a cross-border transfer, and a dossier on it is filed within 60 days of the first transfer (art. 20 part 1 “c”, part 2).

7.Log and rights

  1. 7.1

    The host and the guest can find out which of their data went to whom: fill in: operator’s email.

  2. 7.2

    The address log is kept for fill in: period, then anonymised.