Last modified: February 1, 2020
We are made up of different legal entities with details that can be found https://reservationsoftware.com/RESSOFTworldwideentities. These entities make up our “Company Group” and when we refer to “RESSOFT”, “we”, “us” or “our” in this Policy, we are referring to the relevant Company Group processing your Personal Information. It is important to us that your Personal Information is protected, private and secure, so RESSOFT shall serve as the controller that is responsible for your Personal Information.
We have appointed a data protection officer who is responsible for answering questions in connection with this Policy. If you have any questions regarding this Policy, your Personal Information or the exercise of your legal rights, contact the data privacy officer at the details set out below.
Contact Name: Brian McGuire
Address: 17935 Sky Park Circle, Irvine, CA 92614
Phone: (360) 903-8563
By accessing or using the Website, including purchasing or obtaining our products or services through the Website, you agree to this Policy. If you do not agree with the terms of this Policy, do not use the Website or provide any information to us.
This Policy was last updated on February 1, 2020. This Policy may change from time to time. If there is a material change to this Policy, we will notify you in an appropriate way(for example, by email or pop-up notice when you visit the Website.
- INFORMATION WE COLLECT.
“Personal Information” means information that identifies you or another person as an individual such as your name, mailing address, email address, telephone number, IP address, location or any other identifier by which you or any other individual may be contacted online or offline.
“Non-Personal Information” means information that does not identify you as an individual, such as your browser type, your internet connection, the URL of the previous website you visited, the equipment you use to access the Website, and details about how you use the Website.
The following are categories of information that we may collect (a) when you provide it to us; (b) automatically through the Website; or (c) through third-parties:
“Account Info”: information provided by you when you setup an account with us such as your name, email, birth date, gender, postal code, and country.
“Usage Info”: information about how you use the Website and any of our products or services.
“Technical Data”: information about your technology such as your IP address, browser type and version, time zone settings and location, browser plug in types and versions, operating system and platform, and other devices you use to access the Website.
“Marketing Data”: information regarding our communication with you about marketing such as communication preferences, whether you want to receive marketing information from us or third parties, and what categories of marketing information you wish to receive.
“Payment Data”: information provided when you make purchases through the Website such as your name, date of birth, credit or debit card number, expiration date, bank account, postal code, phone number, and details of your transaction history.
“Voluntary Data”: information that you provide to us about your interests, your responses to surveys, feedback about the products, services, or the Website.
We use aggregated information that includes age, gender and location for any purpose. Aggregated data may be derived from your Personal Information, but is not considered Personal Information and this data does not directly or indirectly reveal your identity.
We do not collect any “Special Categories” of Personal Information about you (such as race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, information about your health, and genetic and biometric data.)
- HOW WE COLLECT YOUR INFORMATION.
We may collect information (a) when you provide it to us; (b) automatically through the Website; and (c) through third-parties.
- Information You Provide to Us. When you use the Website, you may choose to provide us with both Personal and Non-Personal Information, including when you:
- Visit the Website.
- Purchase or obtain our products or services.
- Complete and submit forms on the Website.
- Contact us.
- Enter into a contest or promotion sponsored by us.
- Submit a product review.
- Report a problem with the Website or our products.
- Information We Collect Automatically.
As you use and interact with the Website, we may automatically collect Technical, Usage and/or Marketing Data such as details regarding your access to and use of the Website, log files, product purchase history, browser type, operating system, and device information. If you do not want us to collect this information you may contact us at the contact information in the Introduction. You should understand that my opting-out of the collection of certain Personal Information may prevent us from providing certain products or services to you, and could affect your ability to use all of the features of the Website.
Tracking Technologies. The technologies we use for automatic information collection may include “cookies.” A cookie is a small file placed on your browsing device. It may be possible to refuse to accept cookies by activating the appropriate setting on your computer, tablet, or smartphone. However, if you select this setting you may be unable to access certain parts of our Website.
Do Not Track. Do Not Track is a privacy preference that you can set in your web browser. When you turn on the Do Not Track signal, your browser sends a message to websites requesting them not to track you. For information about Do Not Track, visit www.allaboutdnt.org. At this time, we do not respond to Do Not Track browser settings or signals. In addition, we may use other technology that is standard on the internet, such as pixel tags, web beacons, and other similar technologies, to track visitors to the Website. Those tools may be used by us and by third parties to collect information about you and your internet activity, even if you have turned on the Do Not Track signal.
- Information We Collect from Third Parties. We may receive Personal Information about you from various third parties as set out below:
- Suppliers of alternative accommodation
- Relocation, Business, Employer or other Clients
- Online Travel Agencies (“OTAs”)
- Advertising networks
- Business Partners
- Social Media applications
- Search information providers
- Data brokers / aggregators
- Publicly Available Sources
- WHY WE COLLECT YOUR PERSONAL INFORMATION.
We process your Personal Information only for fair, lawful and legitimate reasons. We may collect information (a) when you provide it to us; and (b) automatically through the Website. The table below listing the categories of Personal Information, the purpose for processing such Personal Information, and on what legal basis:
|Purpose||Personal Information||Legal Basis|
|Make the Website available to you||Name, email address, contact information||To provide requested services|
|Provide you with information, products, or services that you request from us.||Name, email address, home address, contact information||To provide requested services|
|Provide you with product promotion and advertising materials||Name, email address, contact information||To provide requested services|
|Improve our products and services and other business purposes||Name, email address, contact information||Business improvement|
|For legal and safety purposes||Name, email address, home address, contact information||To provide requested services|
|In order to communicate with you||Name, email address, contact information||Business improvement|
We use Personal Information for a number of legitimate interests, including to provide and improve our products and services, administer our relationship with you and our business, for marketing and in order to exercise our rights and responsibilities. More detailed information about these legitimate interests is set out below.
- DISCLOSURE OF YOUR INFORMATION
We disclose your Personal Information to the following categories of recipients:
- Service Providers: to contractors, service providers, suppliers, OTAs, data processors, and other third-parties we use to support our business. These parties are bound by contractual obligations to keep your Personal Information confidential and use it only for the purposes for which we disclose it to them.
- Marketing/Preferred Alliance Partners: to tailor your content or to help us understand your use of the Website in order to provide you with better service, and in order to send you promotional communication about the Website.
- Business Partners or Affiliates: other companies in the Company Group including affiliates, subsidiaries, advisors, partners and consultants who are bound by confidentiality obligations and security measures.
- Business Transfers: to a buyer or successor in the event of a merger, reorganization, dissolution, or other sale or transfer of some or all of our business or assets.
- Law Enforcement: to third-parties such as law enforcement, government entities, courts, or other third parties as required or allowed by applicable law when requested. To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- Controller Interest: If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of RESSOFT, its affiliates, customers, users or others such as fraud agencies.
- INTERNATIONAL TRANSFERS
We are located outside of the European Economic Area (EEA). As a result, when you provide Personal Information to us, that Personal Information is transferred outside of the EEA in order for us to be able to receive and access it. We will only do this with your consent.
- We use external third parties that are based outside the EEA that process your Personal Information in order to carry out activities specified in this Policy. This includes third parties in the following countries: United States. Whenever we transfer your Personal Information to one of these third parties, we ensure that at least one of the following safeguards are implemented:
- We will only transfer your Personal Information to countries that have been deemed to provide an adequate level of protection for Personal Information by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give Personal Information the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to Personal Information shared between the Europe and the US.
- Please contact us at our Data Privacy Officer or RESSOFT if you want further information on the specific mechanism used by us when transferring your Personal Information out of the EEA.
- YOUR CHOICES AND OPTING OUT
We may periodically send you email messages describing news, information, updates, or promotional offers related to the Website or our products and services.
You can “opt-out” of receiving emails from us at any time by following the instructions included in your email or by sending a reply stating your request, and we will make the requested changes. Whether you opt-out of receiving promotional emails or not, we reserve the right to email or otherwise contact you with respect to important information, notices or changes relating to our products and services.
- DATA RETENTION
We will only retain your Personal Information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.
- YOUR LEGAL RIGHTS
You have certain legal rights under applicable data protection laws including the following:
Right to Access: You can request a copy and review the Personal Information we process about you.
Right to Rectification: You can request to amend or update your Personal Information that is inaccurate or incomplete.
Right to Erasure: You can request that we delete your Personal Information where there is no good reason to continue processing it or if it was collected unlawfully. We may not always be able to comply with your erasure request for specific legal reasons, which will be notified to you.
Right to Restrict: You can request that we temporarily or permanently stop processing all or some of your Personal Information if: (a) you want us to establish the accuracy of the Personal Information; (b) where the use is unlawful but you do not want it erased; (c) where you need us to hold it for legal purposes; or (d) you have objected to the use of your Personal Information but we need to verify if we have overriding legitimate reasons for processing the Personal Information.
Right to Object: You can object to us processing your Personal Information on grounds relating to your particular situation. You have the right to object to your Personal Information being processed for direct marketing purposes.
Right to Data Transfer: You can request a copy of and transfer your Personal Information in electronic format to you or a third-party. This right only applies to automated information that you consented to us processing or where we used the Personal Information to perform a contract with you.
Right Not to Be Subject to Automated Decision Making: You have the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.
Withdraw Consent: You have the right to withdraw your consent for us to process your Personal Information. (This does not affect the lawfulness of processing your Personal Information prior to the withdrawal of your consent.)
You may contact our Data Privacy Officer at firstname.lastname@example.org to exercise any of your legal rights. If you are ever not satisfied with our response or believe that your Personal Information is being processed unlawfully, you may contact or lodge a complaint with the competent supervisory authority or seek other remedies under applicable law.
- DATA SECURITY
We have put in place appropriate security measures to prevent your Personal Information from accidentally being lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected Personal Information breach and will notify you of such as soon as possible.
- CHILDREN UNDER THE AGE OF 13
We do not knowingly collect Personal Information from children under the age of 13. If you are under the age of 13, you should not make a purchase, register, or submit Personal Information to us. If we learn that we have collected or received Personal Information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any Personal Information from or about a child under 13, please contact us at Data Privacy Officer at email@example.com.
We may modify or amend this Policy from time to time. The date this Policy was last revised is identified at the top of the page and the terms of this Policy are effective as of that date.
- CONTACT INFORMATION
To ask questions or comment about this Policy and our privacy practices, contact us at Data Privacy Officer at firstname.lastname@example.org.