Last Updated: May 30, 2018
Website and Web Application. As a part of the Services, you may access and login into the Web Application. The Web Application allows you to access certain features of the Services, including but not limited to, those features specific to booking and the vacation guides made available by Company from time to time. You may also share ideas, feedback and other content and materials through your use of the Services, as further described herein. The Website provides users with the chance to learn more about Company, and the ability to post their thoughts and comments to the Website blog. Through the Website, users may view the various services offered by Company, learn more about the Web Application and post comments and thoughts on the Website blog.
How the Services Work. Our Services provide vacation-planning information, in addition to access to third party reservation engines made available via the Web Application.
Children. Protecting the privacy of children is very important to us. We do not collect or maintain Personal Information from people we actually know are under 13 years of age. If you are under 13 years of age, please do not use the Services.
Information We Collect
In general, the Personal Information we gather enables us to provide the Services to you and helps us learn more about the use of the Services.
Specifically, we collect the following types of Personal Information:
Voluntary Information. We also collect other types of Personal Information that you provide to us voluntarily, such as information that you provide directly to us in order to enable us to provide you with the Services. We may also receive requested information if you contact us via e-mail regarding support for the Website.
Bookings Made Online. When you make an online booking with us through the Services, your information is transmitted securely into our property management software. The property management software stores this information on our behalf for purposes of facilitating your reservation with us.
Usage/Account Information. We collect Personal Information that you submit to us voluntarily at registration and in the course of your use of the Website. To use our Services, we may require you to create an “Account” and we will collect your name, mailing/billing address, email address, phone number and location information, where applicable.
Indexing/Third Parties. We may obtain information about you from third parties or through our indexing and analytics tools.
Communications. When you communicate with us by sending us an email, we will collect and store any information that is contained in your communications with us.
Location Information. If you have enabled location services on your phone, we collect your location information to make a map available to the recipients of your messages showing your location. If you do not want this information collected by us, you can disable location services on your phone.
Email Subscribe Forms. To help keep you informed about our latest news, area information, specials and promotions, we may offer the opportunity to subscribe to our email list via various subscription forms throughout the Services. By subscribing you are requesting follow-up information from us and you agree that we will use your provided contact information for marketing purposes. You may unsubscribe to these emails at any time by following the unsubscribe link in the footer of all such communications.
Other: We may also collect Personal Information at other points through our Services that state that Personal Information is being collected.
We collect the following types of Anonymous Information:
Information Collected by Our Servers. To make our Website a more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol (“IP”) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.
Log Files. As is true of most websites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends, administer the Website, track users’ movements around the Website, gather demographic information about our user base as a whole, and better tailor our Website to our users’ needs. For example, some of the information may be collected so that when you visit the Website again, it will recognize you and the information could then be used to serve advertisements and other information appropriate to your interests.
Pixel Tags. In addition, we use “Pixel Tags” (also referred to as clear Gifs, Web beacons, or Web bugs). Pixel Tags are tiny graphic images with a unique identifier, similar in function to Cookies, which are used to track online movements of Web users. In contrast to Cookies, which are stored on a user’s computer hard drive, Pixel Tags are embedded invisibly in Web pages. Pixel Tags also allow us to send e-mail messages in a format users can read, and they tell us whether e-mails have been opened to ensure that we are sending only messages that are of interest to our users. We may use this information to reduce or eliminate messages sent to a user. We do not tie the information gathered by Pixel Tags to our users’ Personal Information.
Disclosure – Analytics.
Information Collected from You About Others. If you decide to invite a third party to create an Account, we will collect your and the third party’s names and e-mail addresses in order to send an e-mail and follow up with the third party. We rely upon you to obtain whatever consents from the third party that may be required by law to allow us to access and upload the third party’s names and e-mail addresses as required above. You or the third party may contact us at FRONTDESK@RIVERSEDGEWINTHROP.COM to request the removal of this information from our database. As part of your use of the Services, we provide you the opportunity to connect automatically with your friends. We employ various techniques in order to facilitate friends finding each other on our service, including offering contact importer tools to facilitate adding to your contacts (including Facebook Friends and contacts in your address book) so that you can more readily ask your contacts to join the Services. With your permission, we will access your address book, call log and SMS log, and import your contacts’ names, e-mail addresses, phone numbers, image, geographic location and Facebook IDs to facilitate automatic connection with your friends. We do this only for contact matching to help your friends and you find each other. Also, when you invite friends to the Services, we will access your Address Book and we will import your contacts names and phone numbers in order to facilitate the invitation. The e-mail that is sent to your friends will come from your e-mail address so that your friends know that you want to invite them to visit the Site. We do not store any passwords you provide as part of the contact import process. We also collect some settings that help us to interpret your data, such as the language and keyboard settings that you have established, and the phone’s carrier, mobile network code and mobile country code.
How We Use Information
We will use your Personal Information to:
- Identify you as a user in our system;
- To provide you with the online booking system made available via our property management system;
- Facilitate the creation of and administration of your Account;
- Allow you to communicate with other users of the Services;
- Provide you with the Services and complete your transactions;
- Provide you with customer support;
- Help understand your needs and tailor the features and content of the Services to you;
- Respond to and, as applicable, fulfill your requests, resolve disputes and/or troubleshoot problems;
- Verify your compliance with your obligations in our Terms of Service;
- Send you administrative e-mail notifications, such as security, or support and maintenance advisories;
- Send newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing purposes;
- Improve the quality and functionality of the Services;
- Share with our third party software and services providers in order to facilitate our communications; and
- Communicate with you about the Services.
We may also use your Personal Information to create Anonymous Information records by excluding information that makes the information personally identifiable to you.
We use the Anonymous Information we collect to analyze trends, administer and improve the Services, gather demographic information about our user base as a whole, and better tailor the Services to our users’ needs. However, we reserve the right to use Anonymous Information for any purpose, and to disclose Anonymous Information publicly without restriction. We provide analytics based upon our customer’s use of the Services to prospective partners, other customers, advertisers and other third parties. We may also disclose, on an anonymous basis, actual statements, verbatim, as made by our customers.
How We Disclose Information
We may also disclose certain Personal Information:
- Third Parties Designated by You. When you use the Services, the Personal Information you provide will be shared with the third parties that you authorize to receive such information (e.g., other individuals that you wish to connect with via the Services).
- Third Party Partners & Property Management Software. We will share the information you provide with us through your use of the Services to make an online booking with the third party that provides our property management software. This information, including your contact information, stay dates and any other information that you share with us via the property management system, may be used for future marketing purposes and as necessary to facilitate current and future bookings through our property management software.
- Third Party Service Providers. We may share your Personal Information with our third party service providers who provide services such as data analytics, website hosting, payment processing (e.g., Stripe), information technology, customer service, email delivery, auditing, and other services.
- Public Profile. Certain portions of the information you provide to us may also be displayed in your Profile. As an essential element of the Services, most of the Personal Information you explicitly provide to us when you register or update your Profile is displayed on your Profile. In order for your Profile to be made public, you must go to your profile settings and then to profile visibility. By default, your Profile is not for public viewing. Your photos, posts, friends, and other content you post through the Services are also meant for public consumption. We may display this content through the Services and further distribute it to a wider audience through third party sites and services. Once displayed on publicly viewable web pages, that information can be collected and used by others. We cannot control who reads your postings or what other users may do with the information that you voluntarily post, so it is very important that you do not put Personal Information in your posts. Once you have posted information publicly, while you will still be able to edit and delete it on the Site, you will not be able to edit or delete such information cached, collected, and stored elsewhere by others (e.g., search engines).
Your Choices Regarding Your Information
- Email Communications. We will communicate with you primarily in the form of emails. You can manage the frequency and/or opt out of receiving these communications by changing your settings in your Account and/or clicking the “Unsubscribe” link at the bottom of each email. Please note that even if you unsubscribe or opt-out, we may still send you Website-related communications (e.g., emails related to your Account).
- Cookies. If you decide at any time that you no longer wish to accept cookies from our Services for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. Consult your browser’s technical information. If you do not accept cookies, however, you may not be able to use all portions of the Services or all functionality of the Services.
- De-Linking SNS. If you decide at any time that you no longer wish to have your SNS account (e.g., Facebook) linked to your Account, then you may de-link the SNS account in the “preferences” section in your account settings. You may also manage the sharing of certain Personal Data with us when you connect with us through an SNS, such as through Facebook Connect. Please refer to the privacy settings of the SNS to determine how you may adjust our permissions and manage the interactivity between the Services and your social media account or mobile device.
- Applications. You can stop all collection of information by the Web Application by no longer using or accessing the Web Application. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network. You may at any time opt-out from further allowing us to have access to your location data.
Information Disclosed to Third Parties
Web Application & Services, Specifically. We may also collect non-personal information from your mobile device if you access our Services from your mobile device. This information is generally used to help us deliver the most relevant information to you. Examples of information that may be collected and used include your geographic location, how you use the Services and information about the type of device you use. In addition, in the event the Services crash on your mobile device, we will receive information about your mobile device model software version and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of our Services. This information is sent to us as aggregated information and is not traceable to any individual and cannot be used to identify an individual.
How We Respond to Do Not Track Signals
We do not currently respond to “do not track” signals or other mechanisms that might enable consumers to opt out of tracking on the Website.
INTERNATIONAL DATA TRANSFERS
Data Protection Officer.
To communicate with our Data Protection Officer, please email FRONTDESK@RIVERSEDGEWINTHROP.COM.
Identifying the Data Controller and Processor.
Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. In general, you are the controller of all data and information submitted through the Services, including all Personal Information. In general, Company is the processor of all such data and information, including Personal Information, and the controller of all other information made available through the Services. Company may provide the Services in different parts of the world but is established in the United States of America and operates out of the United States of America.
Users located in certain countries, including the European Economic Area, have certain statutory rights in relation to their personal data. Subject to any exemption provided by law, you may have the right to request access to information, as well as to seek to update, delete or correct any such information. If you are unable to locate or use the applicable settings, please contact us for additional assistance at FRONTDESK@RIVERSEDGEWINTHROP.COM.
Company may also process any other information that constitutes your Personal Information for direct marketing purposes and you have a right to object to Company’s use of such Personal Information for this purpose at any time.
Information Choices and Changes; Data Protection Authority.
You can prevent the further collection or use of your personal information by terminating your use of the Services.
Opting Out of Marketing Emails. Our marketing emails explain how to “opt-out.” If you opt out, we may still send you non-marketing emails. Non-marketing emails include emails about your accounts and our business dealings with you. You may send requests about your personal information to our Contact Information below such as to change contact choices, opt-out of our sharing of your personal information with others, and review, update, correct or delete your personal information. We will use commercially reasonable efforts to honor your request, provided, however, that videos can only be removed per the procedures outlined above. We may retain an archived copy of your records as required by law or for legitimate business purposes. You can typically remove and reject cookies from our Site with your browser settings. Many browsers are set to accept cookies until you change your settings. If you remove or reject our cookies, it could affect how our Site works for you.