Effective Date: August 1, 2019
Greetings! Our team here at Vacation Rental Partners, Inc. (“Direct” or “VRP”) values your trust and makes it a high priority to ensure the security and confidentiality of the personal information you provide to us. Below you will find our Privacy Notice. We encourage you to please read this notice to learn about our privacy practices so you can better understand what we collect from you, why we collect it and your rights. By accessing or using our site or contacting us, you acknowledge that you have read, understood, and agree to the practices as described in this Privacy Notice. This Privacy Notice may change from time to time (see Changes to our Privacy Notice below). Your continued use of the site after we make changes is deemed to be acceptance of those changes, so please check our Privacy Notice periodically for updates.
What information do we collect?
We collect personally identifiable information from you directly when you register on our site, subscribe to our newsletter, respond to a survey, or fill out a form or input data on our site.
When registering on our site, as appropriate, you may be asked to enter information including your name, e-mail address, mailing address, and phone number.
When you use our site, we and our third party service providers may also collect information that you passively make available to us, including the following:
- IP address (a unique identifier for your computer or other device)
- Mobile device ID
- Services navigation history and habits
- Browser type and language
- Internet service provider (ISP)
- Operating system
- Date/time stamp
- Clickstream data
- Cookies (text files containing small amounts of information which we download onto your computer or device when you visit our website, allowing us to remember you)
Finally, we may collect data about you through our own, or third party, analytics services or other data provider services. For example, we may use Google’s analytics services to determine how you found our website. Or, as another example, if you tell us your company name, we may research your company through third party services.
Information you actively provide us –
Registration information. Our system is available only to registered users. When you register, we will ask that you provide basic information such as your name, address, mobile phone number and email address.
Content. Your use of our system may involve submission of various types of content, such as correspondence with guests, guests’ contact information, etc. The precise types of content depends on the features of the Service you choose to use.
Inquiries. When you submit an inquiry or customer-service request, you may provide additional personal details depending on the inquiry or request.
Information we automatically collect –
Integration data. Our service is particularly aimed for properties listed on and operating through third party platforms such as Airbnb, HomeAway, VRBO, Booking.com, etc (“Third Party Channels”). After you register, you may interconnect our system with each of your accounts on Third Party Channels (each interconnection is named an “Integration”). Once you connect to an Integration, the Service imports the property and guest related data in your accounts on the respective Third Party Channel, such as listings, reservations, past guests, etc.
Analytical usage data. We collect analytical information about your use of our service and your interactions with our system’s interface, your session durations and the web pages you accessed. This may also include basic information about the device you use to access the Service, including its type, operating system, language settings, the Internet Protocol (IP) address through which your device accessed the Service, and the city or town where the device you used to access the Service is located.
How do we use your information?
Any of the information we collect from you may be used in one of the following ways:
- To personalize your experience (your information helps us to better respond to your individual needs)
- To market our services to you
- To improve our website (we continually strive to improve our website offerings based on the information and feedback we receive from you)
- To improve customer service (your information helps us to more effectively respond to your customer service requests and support needs)
- To administer a contest, promotion, survey or other site feature
- To send periodic emails
- For our other business purposes
- Operating our service and providing its features and functionalities
- Sending you notifications, messages, communications and announcements related to our service
- Improving and customizing our service and developing new services
- Providing you with support, handling complaints and contacting you when we believe it is necessary
- Enforcing the Terms and this Privacy Notice and preventing misuse of our service
- Complying with any applicable law and assisting law enforcement agencies and competent authorities, if we believe it is necessary or justified; and
- Taking any action in any case of dispute involving you, with respect or in relation to our service
We also may collect and store information about you that we receive from other sources to, among other things, enable us to verify, update and correct the information contained in our databases, prevent fraud, provide services to our other clients, and to better customize your experience on our site.
Note: If at any time you would like to unsubscribe from receiving future marketing emails, please contact [email protected].
How do we protect your information?
VRP has implemented reasonable physical, technical, and administrative security standards to protect personal information from loss, misuse, alteration, or destruction. We strive to protect your personal information against unauthorized access, use or disclosure, using security technologies and procedures, such as encryption and limited access. Only authorized individuals access your personal information, and they receive training about the importance of protecting personal information.
How long do we keep your personal data?
We store personal data for as long as we find it necessary to fulfill the purpose for which the personal data was collected, while also considering our need to answer your queries or resolve possible problems, to comply with legal requirements under applicable laws, to attend to any legal claims/complaints, and for safeguarding purposes.
This means that we may retain your personal data for a reasonable period of time after your last interaction with us. When the personal data that we have collected is no longer required, we will delete it in a secure manner. We may process data for statistical purposes, but in such cases, data will be anonymized.
We may use the information we collect, as outlined above, to compile anonymized or aggregated information. We may share, sell or otherwise communicate and make available such anonymized or aggregated information to any other third party, at our sole discretion. However, we will not knowingly or intentionally share information that can be reasonably used to reveal your identity without your consent.
Transfer of data outside your territory
We may store and process information in various locations throughout the globe, including through cloud services. The laws in those other countries may provide a lesser degree of data protection than the laws of your own country. You agree to the transfer of your information to such other countries for the purpose of processing as described in this Policy, including through cloud services.
Yes, cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow) that enables the sites or service providers systems to recognize your browser and capture and remember certain information.
If you prefer, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies via your browser settings. Like most websites, if you turn your cookies off, some of our services may not function properly. However, you can still reserve a booking over the telephone by contacting the company’s customer service number directly. Your browser or device may include “Do Not Track” functionality. Our websites and services do not recognize “do not track” signals or similar mechanisms that allow browser users to make a choice about the collection of information that reveals the individual’s online activities, so VRP’s information collection and disclosure practices and the choices we provide will continue to operate as described in this Privacy Notice, whether or not a Do Not Track signal is received.
Do we disclose any information to outside parties?
We may share the information outlined in this Notice, with others, in any of the following instances:
- With contractors and service providers, in order to operate, maintain and enhance the our system, and provide you with the particular features of the system you requested
- With Third Party Channels, in order to maintain your account on the system and on Third Party Channels updated
- Messages you address to guests and prospective guests will be sent to them
- If you have breached the Terms, abused your rights to use our system or violated any applicable law. Your personally identifiable information may be shared with competent authorities and with any third party, if we believe it is necessary or justified
- If the operation of the system is organized within a different framework, or through another legal structure or entity (such as due to a merger or acquisition)
- We may share personally identifiable information with our corporate group entities, but their use of such information must comply with the Notice
We also use third-party service providers who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site’s policies, or protect our or others rights, property, or safety in anyway legally or most appropriate to the situation at our sole discretion.
Occasionally, at our discretion, we may include or offer third party products or services on our website. These third party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites.
Individuals Within the European Union
Legal Bases for Processing Personal Data
If you are an individual located in the European Union (EU), we collect and process personal data about you where we have a legal basis for doing so under applicable EU laws. This means we collect and process your data only when:
- it is necessary for a legitimate interest (which is not overridden by your individual privacy interests), such as preventing fraud, improving our site, and increasing the security of the website and network infrastructure;
- you have consented to this collection and processing for a specific purpose;
- it is necessary to fulfil our contractual obligations; or
- it is necessary to comply with a legal obligation.
Where we rely on your consent to process your personal data, you have the right to withdraw or decline consent at any time. Some examples of where we rely on your consent to process your personal data include sending you marketing emails. If you wish to withdraw your consent, please contact us at [email protected]
Some examples of our legitimate interests for processing personal data include:
- site and network security;
- customer support;
- fraud prevention; or
- improving our site.
Where we rely on our legitimate interests to process your personal data, you may have the right to object. More information on exercising this right can be found in the Individual Rights section below.
If you have any questions about or need further information concerning the legal basis on which we collect and use your personal data, please contact us at [email protected]io.
If you are located in the EU, you have certain rights under EU data protection law with respect to your personal data, including the right to request access to, correct, and delete your personal data. You may also have the right to receive a copy of your personal data in a commonly used and machine-readable format, and to transmit such data to another controller. You also may object to processing of your personal data, or ask that we restrict the processing of your personal data in certain instances.
To request deletion of, access to, or to make changes to your personal data, or to otherwise any of the rights in this section, please contact us at [email protected]. Please note that not all requests can be honored.
Transfers, Storage, and Processing
Our site is operated from and hosted on servers located in the United States. If you access and use our website from a location outside of the United States, any personal data you provide to us or that is otherwise collected may be transferred to and processed in the United States or any other jurisdiction in our sole discretion. Users of our Apps should be aware that the laws that apply to the use and protection of personal data in the United States or other countries or jurisdictions to which we transfer, or in which we process, personal data may differ from those of your country of residence. Users who access or use our site from jurisdictions outside of the United States do so at their own choice and risk and are solely responsible for compliance with local law. While we take steps to safeguard your personal data, the United States has NOT been deemed by the European Commission to ensure an adequate level of protection for personal data. Accordingly, the level of protection provided in the United States or other non-EU countries and jurisdictions from which you may access our Apps may not be as stringent as that under EU data protection standards or the data protection laws of some other countries, possibly including your home jurisdiction.
If we are processing your personal data on behalf of another party, your personal data is transferred across borders to the United States or to other countries or jurisdictions in which we or our third-party associates may process personal data through the use of Standard Contract Clauses.
California Civil Code Section § 1798.83 permits users of our site that are California residents to request certain information regarding VRP’s disclosure of their personally identifiable information to third parties for those third parties’ direct marketing purposes. To make such a request, please send an e-mail to [email protected] specifying that you seek your “California Customer Choice Notice.” In your request, please attest to the fact that you are a California resident and provide a current California address for your response. Please be aware that not all information sharing is covered by these California privacy rights requirements and only information on covered sharing will be included in our response. This request may be made no more than once per calendar year. Please allow up to thirty days for a response.
VRP’s sites are a general audience websites and do not offer services directed to children. If you are not at least 18 years old, you may not use our sites. We do not knowingly or intentionally collect information about children who are under 13 years of age. If you believe that VRP has been provided with the personal information of a child under 13 without parental consent, please notify us immediately at [email protected].
Additional Terms and Conditions
Please also visit our Terms of Service which establishes the use, disclaimers, limitations of liability, and other terms and conditions governing the use of our site and services.
This Privacy Notice is made a part of and incorporated into our Terms of Service; any capitalized terms used but not defined in this notice shall have the same meanings as set out in the Terms of Service.
By using our site, you consent to our Privacy Notice and Terms of Service.
We may change our ownership or corporate organization while providing our sites or services. We may also sell certain assets associated with the sites or services. As a result, please be aware that in such event we may transfer some or all of your information to an entity acquiring all or part of our assets or to another entity with which we have merged. Under such circumstances we would, to the extent possible, require the acquiring party to follow the practices described in this Privacy Notice, as it may be amended from time to time. Nevertheless, we cannot promise that the acquiring or merged company will have the same privacy practices or treat your information the same as described in this Privacy Notice.
Changes to our Privacy Notice
We reserve the right to modify or amend the terms of this Privacy Notice from time to time. Your continued use of our sites or services following the posting of changes will mean you accept the new Privacy Notice as modified. If we decide to change our Privacy Notice, we will post those changes on this page and they will be effective immediately.
This policy was last modified on August 1, 2019.
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