VIRGIN HOTELS PRIVACY NOTIFICATION
Effective Date: October 14, 2020
Table of Contents:
The data about you we collect depends on the Site and Services and features thereof that you use and the other services from Virgin Hotels that you use, and includes the following:
1.2 Personal Information.
In general, we collect Personal Information that you submit to us in the process of creating or editing your account and profile on the Site or that you submit to us voluntarily through your use of the Site or when you visit/stay as a guest at one of our properties, purchase related services and interact with us offline. Information that identifies, relates to, describes, is capable of being associated with, or could be linked, directly or indirectly, with a particular consumer or household is “Personal Information.”
In some instances, you may provide to us Sensitive Personal Information or Special Categories of Personal Data as defined by the privacy laws in some countries (together “Sensitive Personal Information“). The specific categories may vary between countries but for Europeans this means personal information from which we can determine or infer an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health information including physical or mental health condition, medical treatment, genetic data, biometric information, and information about an individual’s sexual life or sexual orientation. We only process Sensitive Personal Information to the extent permitted by applicable law. Generally you are not required to provide Virgin Hotels with any of your Sensitive Personal Information, and, unless required by law or for the purposes of health and safety, choosing not to do so will not prevent you from purchasing any Services from Virgin Hotels. We do not generally collect Sensitive Personal Information unless it is volunteered by you. For example, we may use health information provided by you to serve you better and meet your particular needs, such as for the provision of disability access.
Personal Information does not include information that has been de-identified or otherwise made anonymous or information that has been aggregated such that it is no longer possible to identify any specific individual.
The Personal Information which we collect includes, but is not limited to, the following circumstances and data elements:
- If you express an interest in obtaining additional information about our Services, request customer support, use the “Contact Us” or similar features on our Site, register to use our Sites or Services, or download certain content, we may require that you provide to us your contact information, such as your name, organization, phone number, or email address, and in some instances, you may elect to provide us with location and address information;
- If you report a problem or have a question about our Services, you may provide us with contact information, such as a phone number or email address;
- If you decide to stay at one our hotels, we may collect:
- Travel-related information, such as your frequent flyer number, hotel loyalty, honors or rewards numbers, The Know program membership number, account information from third party operators within our branded hotels, preferred airlines, rental car providers, and travel history;
- Your demographic information, such as your date of birth, gender, number of children;
- Your financial and billing information, such as billing name and address, business title, work contact address, credit card number or debit card number;
- Information about your travel preferences or relating to your reservation, such as the properties you have visited, your arrival and departure dates and any special requests you may make, your guest preferences (including those relating to amenities, facilities, housekeeping and room preference), vehicles you may bring to the properties, on-property services that you may request (including concierge services, health clubs, spa services, activities, child care services, equipment rental, and restaurant or room delivery services);
- Information collected through the use of a close circuit television system, internet systems, smart or mobile device, card key and other security and technology systems;
- If you enroll and participate in our guest loyalty program, including The Know or other hotel brand guest loyalty program, we may collect contact information, such as name, email address, mailing address, zip code, and phone number;
- If you or your organization plans an event or meeting at one our facilities, we may collect Personal Information related to the event or meeting such as the guest list and information about the guests at your event;
- If you use and interact with our Sites or emails, we automatically collect information about your device and your usage of our websites or emails through cookies, web beacons or similar technologies, such as Internet Protocol (IP) addresses or other identifiers, which may qualify as Personal Information under applicable law;
- If you voluntarily submit certain information to our Services, such as filling out a survey about your guest experience or entering a contest or promotion, we collect the information you have provided as part of that request.
We may obtain both personal and non-personal information about you from business partners, contractors, suppliers, and other third parties and add it to your account information or other information we have collected. We, and the third parties we engage, may combine information we collect from you over time, and across the Site, with information obtained from other sources. This helps us improve the information’s overall accuracy and completeness, and also helps us better tailor our interactions with you.
1.3 Automatically Collected Usage and Device Information.
B. Other technologies (aka tags/pixels/web beacons/web bugs/java script).
These technologies may be used for the same purposes as cookies and stored on your hard drive until they expire. These technologies are used to enhance your experience and gather usage and performance data. For example, we may use pixels to automatically record certain technical information about your interactions when you visit the Site or otherwise engage with us, to help deliver cookies on our Site, or count users who have visited the Site. We may also include web beacons in our promotional e-mail messages or newsletters to determine whether you open or act on them for statistical purposes. “Pixels” are tiny graphics (about the size of a period at the end of a sentence) with unique identifiers used to track certain online actions, movements and related information of Site users. Unlike cookies, which are stored on a user’s computer hard drive, pixels are embedded invisibly on web pages or in HTML-based emails. The data we receive through pixels allows us to effectively promote the Site to various populations of users, and to optimize external advertisements about the Site that appear on third-party websites. For more information, please see our Cookie Notice. As with cookies, we use these technologies for the preservation of our legitimate interests, to provide a service that is requested by you and, where applicable, on the basis of your consent.
C. Third Party Analytics Providers.
1.4 Location Information.
We collect precise geolocation data from you or your device, as well as your address information, e.g., billing address, when you set up your account and order our services. We also collect and use information about your general location (e.g., your state of residence) and can infer your approximate location based on your IP address in order to track our general Site usage or to tailor any pertinent aspects of your user experience to the region where you are located.
If you grant us access to your location in our mobile application, Lucy, we may collect information about your location. Your location can be determined by: GPS, IP address, and information about things near your device, such as Wi-Fi access points and cell towers. When you use our Services via a wireless device, we may solicit your permission to collect your location data. Some features within our Sites may only function upon confirmation of your location, and therefore such features will not be available if you choose not to provide your location data to us. The specificity of the location data collected may depend on a number of factors, including the device you are using (e.g. laptop, smartphone or tablet) and how you are connected to the Internet (e.g., via cable broadband connection, WiFi). If you enable location services for our mobile application or other Sites, we may collect location data periodically as you use or leave open our mobile application. We may associate such location data with Personal Information you provide to us. Depending on the platform you use to access our mobile application and other Sites (e.g., Apple’s iOS, Google’s Android), you may be able to control whether location data is collected from within “Settings” or other controls on your wireless device or the mobile application.
1.5 User Contributions.
You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Site or transmitted to other users of the Site or third parties, including, for example, third party websites and services like Social Media that are integrated into or linked to the Site (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. We cannot control the actions of other users of the Site or third parties with whom you may choose to share your User Contributions. Such third parties may have their own policies and terms that apply to your User Contributions, and we are not responsible for any third party’s policies or terms. We cannot and do not guarantee that unauthorized persons will not view your User Contributions.
1.6 Social Media.
We use third party service providers to serve advertisements or collect data on our behalf across the internet and on this Site (“Advertisers”). Some of these Advertisers may collect your Personal Information about your Site visits and your interactions with our products and services to tailor marketing messages on other sites, or to trigger real-time interactions, customize the Site, or enhance your profile (also referred to as “online behavioral advertising” or “interest-based advertising”). If you would like more information about Advertisers’ practices, please see http://optout.aboutads.info/#!/. You may find more information about entities involved in online advertising and additional choices you may make, including opt-out of having your information used for internet-based advertising, through the Digital Advertising Alliance (the “DAA”) at the DAA consumer choice service. The tools provided at the DAA opt-out page are provided by third parties, not Virgin Hotels. Virgin Hotels does not control or operate these tools or the choices that advertisers and others provide through these tools. For more details on this technology and for details of how you may be able to opt-out of the use of your information for this purpose see our Cookie Notice.
We may use or disclose the Personal Information identified above for one or more of the following business purposes (“Business Purpose”):
- To fulfill or meet the reason you provided the information (e.g., to help provide lodging and services to you). For example, we need your contact details to make the booking and payment card details in order to take payment from you.
- To create, maintain, customize and secure your account with us.
- To process your information for marketing and promotions, including to check your eligibility for competitions and to contact you in the event that you win, and to administer our rewards program.
- To personalize your experience and to deliver content and product and service offerings, products, and services relevant to your interests, including offers and advertisements through third-party sites, and via email (with your consent, where required by law).
- To help maintain the safety, security, and integrity of our Site, services, databases, other technology assets, and business.
- For testing, research, analysis, and product development, including to develop and improve our Site and services.
- To personalize and develop our Site and the services we provide to you, and improve our offerings.
- To provide certain features or functionalities on the Site.
- To provide you with support, to communicate with you and respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses (including on Social Media).To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- To prevent illegal activity, fraud, and abuse.
- For the defence or establishment of legal claims. We will not delete your Personal Information if it is relevant to an investigation or a dispute. It will continue to be stored until those investigations or disputes are resolved.
- When we need to for our legitimate interests to generally administer our operations and business in an efficient and effective way, to improve and develop our services and to research and analyse the services our customers want.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our users is among the assets transferred or liquidated.
- Or as otherwise described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
3.2 Account-Related Emails.
When you create an account with us and provide us with your email we may, subject to applicable law and, where necessary, obtaining your consent, use your email address to send you service-related notices (including any notices required by law, in lieu of communication by postal mail), updates, news, and marketing messages. For example, when you register, you will receive a welcome email. If the Site or our services are temporarily unavailable, we may also send you an email.
Email communications you receive from us will generally provide an unsubscribe link or instructions allowing you to opt out of receiving future emails or to change your contact preferences. If you have an account with us, you can also change your contact preferences by updating your contact information within your account settings. Please remember that even if you opt out of receiving marketing e-mails, we may still send you important service information related to your account and the Site. If you correspond with us by email, we may retain the content of your email messages, your email address, and our responses.
3.3 Non-Personally Identifiable Information.
We may use non-personally identifiable information, such as anonymized and/or aggregated website usage data, in any manner that does not identify individual users for the purpose of improving the operation and management of the Site, including to develop new features, functionality, and services, to conduct internal research, to better understand Site usage patterns. Any non-personally identifiable information that is combined with Personal Information will be treated by us as Personal Information.
When we disclose Personal Information for a Business Purpose, we ensure we have an appropriate legal basis for such disclosure and, where necessary under applicable law, enter into a contract that describes the purpose and requires the recipient to keep that Personal Information confidential and use only for performance of the contract, and not for any other purpose. We share or make your information available, including any Personal Information, in the circumstances described below.
We disclose your Personal Information for a Business Purpose to the following categories of third parties:
- Social Media networks.
- Analytics Providers.
- Property owners and management companies of our hotels who may use your personal information to fulfil your requests and communicate with you about services or resources that we offer.
- Payment Processors or other providers of payments services.
- IT Suppliers, including cloud hosting providers and email providers.
4.1 Legal Requirements.
We reserve the right to disclose all information collected via the Site, internally, to affiliates, or to third parties, for any lawful purpose or to prevent harm to us or others. For example, and without limitation, in our discretion, we may disclose information to government regulators, law enforcement authorities or alleged victims of identity theft. We will notify you in the event of a government or legal request for your information unless otherwise prohibited by law.
4.2 Organizational Transitions.
You may have certain rights relating to your Personal Information, subject to local data protection law. Whenever you choose to be a guest or visitor at one of our managed properties, we aim to provide you with choices about how we use your Personal Information. Subject to applicable law, you may obtain a copy of Personal Information we maintain about you. In addition, if you believe that Personal Information we maintain about you is inaccurate, subject to applicable law, you may have the right to request that we correct or amend the information by contacting us as indicated in the “Privacy Questions and Contact Information” section below. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to the information.
You can choose not to provide Personal Information. If you choose not to provide certain Personal Information to us, some of your experiences may be affected (e.g., we cannot take a reservation without your name and contact information).
5.1 Online Tracking Choices.
Some web browsers incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have the user’s online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain information about that browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many website operations, including the Site, do not respond to DNT signals.
We use certain physical, managerial, and technical safeguards designed to preserve the security of your information that we maintain in connection with your use of the Site. For example, we encrypt all data with secure sockets layer (SSL) or similar technologies when we transmit your data. This, however, does not guarantee that your information may not be accessed, disclosed, altered, or destroyed by any breach of our physical, technical or managerial safeguards. In the event that any of your Personal Information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and will notify you, as appropriate, in accordance with pertinent laws and regulations.
7.2 Data Retention.
- At any time, you can follow a link provided in offers, newsletters or other email messages (except for e-commerce confirmation or service notice emails) received from us to unsubscribe from such communications and services.
Please be aware that we are headquartered in the United States. The Site is governed by United States law. If you are using any of our products or services from outside of the United States, your information may be transferred to, stored, and processed in the United States where our servers may be located. The United States might not offer the same level of privacy protection as the country where you reside or are a citizen.
Your Personal Information will only be transferred to the United States or other jurisdiction outside the EEA and UK if there is a safeguard in place to ensure an appropriate level of data protection for your Personal Information.
Our website is not intended for children under 18 years of age. We do not intentionally gather Personal Information about individuals who are under the age of 18. If a child has provided us with Personal Information, a parent or guardian of that child may contact us to have the information deleted from our records. If you believe that we might have any information from a child under age 18, please contact us at firstname.lastname@example.org.
Mailing Address: Virgin Hotels, 3390 Mary Street, Suite 218, Miami, FL 33133, U.S.A.
Whenever we collect Personal Information from you or otherwise process Personal Information about you, we do so on the following legal bases:
- Your consent to such collection and use (for example, in some jurisdictions, we may need your consent in order to process your Personal Information for direct marketing activities, when using technology such as cookies or when processing your dietary requirements);
- Out of necessity for the performance of an agreement between us and you, such as your agreement to use our Services or your request for Services;
- Our legitimate interest, including but not limited to the following circumstances where collecting or using Personal Information is necessary for:
- Intra-organization transfers for administrative and other legitimate business purposes;
- Product development and enhancement, where the processing enables Virgin Hotels to enhance, modify, personalize, or otherwise improve our Services and communications for the benefit of our visitors and guests, and to better understand how people interact with our Sites;
- Fraud detection and prevention;
- Defence or establishment of legal claims;
- Enhancement of our, our employees and third parties’ (such as guests) security (including cybersecurity, including improving the security of our network and information systems);
- General business operations and diligence (for example, to develop and maintain relationships with vendors, partners and other organizations and dealing with individuals who work for them); and
- Providing our products and services to you,
provided that, in each circumstance, we will weigh the necessity of our processing for the purpose against your privacy and confidentiality interests, including taking into account your reasonable expectations, the impact of processing, and any safeguards which are or could be put in place. In all circumstances, we will limit such processing for our legitimate business interest to what is necessary for its purposes.
- Out of necessity to comply with a legal obligation: for example, we may need to disclose your data to a law enforcement agency;
- Out of necessity to protect your or other individuals’ vital interests: in exceptional circumstances (for example, health related emergencies), we may need to disclose your information to third parties (for example, healthcare providers).
Where we are using your Sensitive Personal Information, we will only do so if required by law, for the purposes of health and safety, or on the basis of your explicit consent (where such consent is required under applicable laws).
Europeans and those persons who reside in the European Economic Area may have rights under European data protection laws. These rights are summarized below. These rights are not applicable in all circumstances and exemptions may apply.
These rights include the following:
- Access – You are entitled to ask us if we are processing your information and, if we are, you can request access to your Personal Information (commonly known as a data subject access request). This enables you to receive a copy of the Personal Information we hold about you and to check we are lawfully processing it.
- Correction – You are entitled to request that any incomplete or inaccurate Personal Information we hold about you is corrected.
- Erasure – You are entitled to ask us to delete or remove personal data in certain circumstances. There are also certain exceptions where we may refuse a request for erasure, for example, where the personal data is required for compliance with law or in connection with legal claims.
- Restriction – You are entitled to ask us to suspend the processing of certain of your Personal Information if, for example, you want us to establish its accuracy or the reason for processing it.
- Transfer – You may request the transfer of certain of your Personal Information to another party in some circumstances. To help with that you have a right to ask that we provide your information in an easily readable format to another company.
- Objections – Where we are processing your Personal Information based on a legitimate interest (or those of a third party) you may object to processing on this ground. However, we may be entitled to continue processing your information in certain circumstances. Where your Personal Information is processed in order to send you direct marketing, you are entitled to object to this at any time.
- Withdraw Consent – Where you have provided your consent to the collection and processing of your Personal Information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.
- Right to lodge a complaint with a data protection supervisory authority at any time – You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable request does not require you to create an account with us. We will only use Personal Information provided in a verifiable request to verify the requestor’s identity or authority to make the request.
If you request to exercise your rights under European data protection laws, we will respond to your request within one month of its receipt (or within three months of its receipt at the latest, if we require more time and such extension is permitted European data protection laws).
We may require more time in particular where we have received a large number of requests or complex requests. In such cases, we will inform you of the reason and extension period in writing.
We will deliver our written response electronically (unless you request otherwise). Your rights will be exercisable subject to limitations as provided for by European data protection laws. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a reasonable cost estimate before completing your request.
We retain your personal data for as long as necessary for the purpose for which they were initially collected, to carry out legitimate business interests, as well as on the basis of applicable legal requirements (such as applicable statutes of limitation). After expiry of the applicable retention periods, your Personal Information will be deleted. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further use of such data.
The criteria we use to determine the retention period is as follows:
- when your most recent stay at one of our hotels occurred;
- whether there are contractual or legal obligations that exist that require us to retain the data for a period of time;
- whether there is an ongoing legal claim that relates to any business (or otherwise) relationship you have with us, or that is otherwise related to your relationship with us;
- whether any applicable law, statute, or regulation allows for a specific retention period; and
- whether the Personal Information is considered to be Sensitive Personal Information, in which case a shorter retention period generally would be applied.
These criteria may also mean we adjust the period of time we retain the categories of Personal Information detailed above.
Information Collected About Californians.
In the past twelve (12) months, we have obtained the following categories of Personal Information from California users.
|A. Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, passport number.||YES|
|B. Personal Information (including, in respect of individuals in the United States, the categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))).||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some Personal Information included in this category may overlap with other categories.||YES|
|C. Protected classification characteristics under California, federal law.||Physical or mental disability, sex (including gender, gender identity.||YES|
|D. Commercial information.||Products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies, such as food and beverage orders and preferences, room preference.||YES|
|E. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||YES|
|F. Geolocation data.||Physical location or movements.||YES|
|G. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||NO|
|H. Professional or employment-related information.||Current or past job history or performance evaluations.||YES|
|I. Inferences drawn from other Personal Information.||Profile reflecting a person’s preferences for hotels and travel destinations.||YES|
- Directly from our guests or their agents. For example, from information that our guests provide to us in order to reserve a room at a hotel location.
- Indirectly from our guests or their agents. For example, through information we collect from our guests in the course of providing Services to them.
- Directly and indirectly from activity on our website (www.virginhotels.com). For example, from website usage details that are collected automatically. In addition, like many companies, we use “cookies” which are small text files a website can use to recognize repeat users, facilitate the user’s ongoing access to and use of the site and to track usage behavior of, for example, the webpages you visit.
- From Social Media websites.
- From strategic business partners that assist us in providing certain transactions and services (e.g. reservations and bookings service providers, online travel agencies, credit card providers, payment processing, Social Media, product vendors, advertising networks, analytics providers, hosting and other strategic partners).
In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for one or more business purposes:
- California Customer Records Personal Information categories;
- Internet or other network activity information;
- Commercial information;
- Internet or other similar network activity;
- Employment; and
- Geolocation Data.
In the preceding twelve (12) months, we have not sold Personal Information.
The CCPA provides California residents with specific rights regarding their Personal Information. This section describes those rights and explains how Californians may exercise those rights.
- Right to Access Your Data. You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Any disclosures we provide will only cover the 12-month period preceding the receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
- Right to Data Portability. You have the right to a “portable” copy of your Personal Information that you have submitted to us. Generally, this means you have a right to request that we move, copy or transmit your Personal Information stored on our servers or information technology environment to another service provider’s servers or information technology environment.
- Right to Delete Your Data. You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete your Personal Information from our records, unless an exception applies.
- Right to Non-Discrimination for the Exercise of Your Privacy Rights. You have the right not to receive discriminatory treatment by us for exercising your privacy rights conferred by the California Consumer Privacy Act.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the Personal Information, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation and any instructions from courts of lawful jurisdiction.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
This section explains how California residents can exercise their rights. To exercise your rights under the CCPA to access, data portability, and data deletion as described above, please submit a verifiable consumer request to us by either:
- Calling us at 1-833-217-8626
- Emailing us at email@example.com
- Completing this form online.
Only you, or a person that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.
Making a verifiable consumer request does not require you to create an account with us.
We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Upon receiving your request, we will confirm receipt of your request by sending you an email confirming receipt. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information. In some instances, such as a request to delete Personal Information, we may first separately confirm that you would like for us to in fact delete your Personal Information before acting on your request.
We will respond to your request within forty-five (45) days. If we require more time, we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
In some cases our ability to uphold these rights for you may depend upon our obligations to process Personal Information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, listed below, or because processing is necessary to deliver the Services you have requested. Where this is the case, we will inform you of specific details in response to your request.
California Civil Code § 1798.83 permits users who are California residents to obtain from us once a year, free of charge, a list of third parties to whom we have disclosed Personal Information (if any) for direct marketing purposes in the preceding calendar year. If you are a California resident and you wish to make such a request, please send an e-mail with “California Privacy Rights” in the subject line to firstname.lastname@example.org. In your request, please attest to the fact that you are a California resident and provide a current California address for our response. Please be aware that not all information sharing is covered by the California privacy rights requirements and only information on covered sharing will be included in our response.
We Do Not Sell Personal Information As Such Activity Would Be Defined Under Nevada Privacy Law.
As a Nevada resident, you may request that we stop selling certain categories of Personal Information that we collect. We have not sold Personal Information of our guests or Site users as contemplated by NRS Ch. 603A, Sec. 2(2)).