Updated February 18, 2024
3. THIRD PARTY SITES AND SERVICES
Third party companies, sites and services, such as our business clients (which may include property management companies, property owners, travel booking companies, or other travel partners (collectively “Clients”)), advertisers, promotional partners, and other service providers accessible through our Services, or third-party sites and services on which we advertise, may have their own privacy and data collection policies and practices. For example, during your visit to our Sites you may link to, or view content that is created or hosted by a third party. Rentalz is not responsible for the actions or policies of such third parties and is not liable to you for any claims that may arise from your interaction with those third parties or their sites. You should check the applicable privacy policies of those third parties when providing personal information on a feature or page operated by a third party.
4. OWNERSHIP OF INFORMATION
5. CATEGORIES OF PERSONAL INFORMATION WE COLLECT
- Identity Data, such as your name; address; email address; telephone number; account login data, e.g. username and password; and certain demographic data.
- Contact Data, Identity Data we can use to contact you, such as email, physical addresses, and phone numbers. such as your name, email address, physical address, phone number.
- Transaction Data, including Information collected in connection with a rental or listing transaction (such as the home you rented, price, dates of your stay, information about properties you own or manage and which you want to list on our Services) , or other data provided when you engage in any transaction on our Services.
- Financial Data, including Information relating to financial accounts or services, e.g. a credit or debit card number, other financial account number you provide in connection with your payment to us for Services, or our payments to you if you are a Client listing your rental properties with our Services.
- Device/Network Data, such as information on which areas of our Sites you visit or what content you search on our Sites, IP Address, MAC Address, SSIDs or other device identifiers or persistent identifiers, online user ID, device characteristics (such as browser/OS version), web server logs, application logs, browsing data, cookies, and other tracking technologies associated with your devices.
, including recordings collected from your telephone calls with us or our service providers, audio files and records, such as voicemails, call recordings, and the like.
General Location Data
, including general location information derived from your Device/Network Data, such as your IP address (note, this information is not precise).
- User Content, including search terms, inquiries, feedback, or other information you provide through the Services in free text fields such as when you input inquiries into our Jini Service, in comment boxes, answers you provide when you participate in sweepstakes, contests, and surveys, or other content you create and provide.
- Preference Data, such as information relating to your requests, the time of year you traveled, the regions in which you have booked or searched for accommodations or travel information, and your “likes” or “favorites.”
- Inference Data, including Information we may use to create a profile about you reflecting your preferences, characteristics, and your interests (e.g. if you travel to certain destinations at certain times of year, we may infer that you intended to ski, golf, or attend a film festival).
6. SOURCES OF PERSONAL INFORMATION
Information you voluntarily provide
When you create an account as a customer or Client, or access or use our Services (whether on our Sites, through Services we enable our Clients to provide on their own sites, or through white-label versions of our Services), you may voluntarily submit Personal Information or other Information, such as requesting information on a particular rental property or vacation destination, providing details regarding a property you manage (for potential listing on our Services), submitting travel planning inquiries, or Information you provide when you otherwise interact with us. Depending on the nature of your interaction with our Services and which specific Service you interact with, this may include your Identity Data, Contact Data, Preference Data, Transaction Data, Financial Data, and User Content. Depending on the Services and the way in which they are implemented, some of this data may be owned by Rentalz, and other data may be owned by our Clients.
Information collected automatically
When you use our Services, some types of Information will be automatically collected, even if you don’t participate in a transaction. This may include Device/Network Data and other data generated through applications and browsers, including cookies and similar technologies. Data may include the date/time you accessed our Services, the referring site, pages you visited and content you viewed when you were on our Services, other session navigation history, similar browsing metadata, and General Location Data. We will also collect Transaction Data automatically if you enter into a transaction with us, and we automatically record certain telephone calls to some of our Services, resulting in the collection of Audio Data.
Information we receive from third-party sources
We may receive Personal Information from: our Clients, our business partners, our affiliated companies, third party sites, sites on which we advertise properties, ad networks, behavioral advertising vendors, market research companies, social media companies, and from third party data aggregators, data brokers, or certain government records (such as local property ownership records). These third parties may share Personal Information with us including Identity Data, Contact Data, Transaction Data, Preference Data, Inference Data, Device/Network Data, or other Information. We license Personal Information regarding home owners, including vacation rental property owners, as well as travelers, from third party data brokers, who may obtain the Personal Information from public records or a variety of other sources. We may also append Identity Data, Contact Data, Preference Data, Inference Data and other Personal Information we receive from these third party sources to our own records and records we receive from our Clients, in order to provide certain marketing Services and deliver relevant information to our Clients’ customers, as well as travelers and other users in our own systems.
Information we create and infer
We, certain partners, social media companies, and third parties operating on our behalf create and infer Personal Information based on our observations or analysis of other Personal Information processed by Rentalz as part of our Services, and we may correlate this data with other data we process about you to create Inference Data. We may create “Profiles” of individuals by combining any Personal Information about you that we or our affiliated companies receive from you and from third parties, including any of the sources listed above, in order to provide information we believe would be of interest to you. As a service provider to our Clients, we also use this Inference Data to provide more detailed information to our Clients regarding their own customers, and to help our Clients target their messaging to appropriate individuals, as part of our Services.
6. USE OF INFORMATION – NOTICE AT COLLECTION
Rentalz and our affiliated companies may use and process Information collected through our Services or received from third party sources for the following purposes:
· Site Registration: If you register to create an account on one of our Services, we may collect your Contact Data, Identity Data and Device/Network Data in connection with that account. We will then process that Personal Information whenever you log in to that Service in the future.
· Facilitating Rental Transactions: If you book a rental property through our Services, we ensure that your Identity Data, Contact Data, Transaction Data, and other Information you provide in connection with a rental is submitted to the property manager or other local third-party booking agent to facilitate a rental transaction between our users and property owners or managers. Please note that if you book a rental through our Services, the transaction and payment will be carried out by the third party Client with whom you are booking, rather than Rentalz.
· Rental Listings: If you register to list rental properties on our Services, we may collect and use your Identity Data, Contact Data, Transaction Data, Financial Data, details regarding your properties, and other Information to create user accounts, list your properties on our Sites, provide Services, issue payments, and to manage your listings, calendars, and other details related to your properties.
· Service Communications: We use your Identity Data, Contact Data, Transaction Data, Audio Recordings, Inference Data and other Information you provide in your various communications with us (via email, phone call, or otherwise), such as when you make an inquiry and we respond, when we remind you to complete a transaction you may have started, communications about your property listings, when you place a call to us, and in connection with other customer service functions.
· Answering Services: If you call and speak with our customer service team regarding a rental property or leave a message for one of our Clients through our AnswerPoint service, we will answer your questions to the best of our ability and will ensure that the applicable Client receives your message and applicable information you may provide. We will not keep messages or call recordings for our Clients beyond the period designated in our Client contracts, as this Information is owned solely by our Client.
· Service Improvement and Personalization: We may use Identity Data, Contact Data, Preference Data, Transaction Data, and other Information to personalize our Sites (for example, to show you properties or locations we believe would be of interest to you), for troubleshooting, to improve the functionality and quality of our Services, and to optimize our Services to make them more useful to our Clients and other users. This information also allows us to better tailor our content to your needs and to help our affiliated companies, Clients and advertisers to better understand our audience.
· Compliance, Health, Safety, Public Interest: We may also process Personal Information as necessary to comply with our legal obligations, such as where you exercise your rights under applicable data protection laws, for the establishment and defense of legal claims, where we must comply with requests from government or law enforcement officials, and as may be required to meet national security or law enforcement requirements or prevent illegal activity. We may also process Personal Information to protect the vital interests of individuals, or on certain public interest grounds, each to the extent required or permitted under applicable law.
· Personalized Marketing Communications: We may personalize various marketing communications to you, whether sent by Rentalz on our own behalf or on behalf of our Clients, through email, on social media, or otherwise (collectively “Marketing Communications”) and target them to you based on Personal Information we have collected about you, information from our Clients, as well as Inference Data and your Profile. When we send Marketing Communications on behalf of our Clients, we may send those communications to our Clients’ email lists, and as part of the Services provided to our Clients, we may enhance those communications with information received from third parties, and other information we believe would be of interest to you.
· Data Sales: We may engage in “sales” of Personal Information as defined by applicable privacy laws. For example, we may “sell” certain Personal Information to our Clients when we engage in marketing campaigns on their behalf or to help them better tailor their messaging to potential customers. We may also engage in the sale of Personal Information when we conduct Targeted Advertising, or we may sell or grant access to Personal Information to our marketing partners, in relation to Targeted Advertising, joint promotions, and other marketing initiatives. See the California Rights & Disclosures section below for a list of categories of Personal Information sold or as defined by California law, “shared” for Targeted Advertising.
· Promotions: If you enter a promotion on our Sites, such as a sweepstakes or contest, we will use your Identity Data and Contact Data to contact you in connection with that promotion and may send you additional information as described in the rules of that promotion. If you win a promotion, your acceptance of a prize may allow us to make certain Personal Information public, e.g. posting your name on a winner’s page. See the applicable program’s terms for details.
· Data Analytics and Targeting: We use Personal Information collected through our Services, from our Clients, from data brokers and from other third parties to determine which destinations, travel options or other offerings may be of interest to you, and we may periodically send you emails on behalf of our Clients or from Rentalz or our affiliated companies, regarding vacation destinations, rental properties, or other offers, products or services we believe may be of interest to you. We may also facilitate data analytics on behalf of our Clients and may license data to our Clients for the purpose of helping them to better understand and promote their services and offers to their current and prospective customers.
· Data Supplementation: Information obtained from cookies and similar technologies, Transaction Data, Inference Data, or other Personal Information may be combined with Personal Information from our Clients, data brokers or other sources in order to append, correct, or supplement Personal Information we or our Clients already have. For example, our Clients may upload their own customer information to our Services in order to query our database so they can determine which of their customers may have traveled to a certain destination, or to match other travel preferences. We may also sublicense certain Personal Information to our Clients to allow them to identify potential new customers. This allows our Clients to more effectively promote relevant offers, and allows our users to receive marketing communications that are pertinent to their interests. We may also use Information sent to us by your web browser or by cookies to perform statistical analyses of our server logs in order to study the use of various areas of our Sites. We review IP addresses to analyze where we are getting our audience. We may create aggregate reports on our users’ traffic patterns and other user data for current or future affiliated companies, advertisers, sponsors and partners.
7. SHARING OF INFORMATION
· We may share Information collected through our Services with various third parties as follows:
· In order to facilitate your transaction, streamline our business operations, improve our Services, and develop products and services that better meet your interests and needs, we may share your Information with our current or future affiliated entities.
· If you inquire or book a rental through our Services, we may share your Identity Data, Contact Data, Transaction Data, Preferences and certain User Content related to the inquiry or booking with owners or managers of the applicable rental properties.
· If you make a payment for a rental property through our Services, that Financial Data will be transmitted directly to our Client and to payment processors engaged by our Client. If you pay to subscribe to one of our Services, or if we need to pay you in connection with a rental of your property, we may share Financial Data and Identity Data, Contact Data or Transaction Data with payment providers and relevant financial institutions as needed to process your payment or in connection with a chargeback or for fraud detection and prevention purposes, and we may also share limited payment information (such as confirmation of a payment being processed, or sending a check for payment) with the property owner/manager or our affiliated entities.
· We share relevant Information with companies and organizations that perform services on our behalf (as applicable depending on the services they provide). For example, Information may be accessed by or shared with companies that provide support services to us (such as data storage, web hosting, email services, marketing services, and other services).
· We share certain Preference Data and Inference Data with our Clients when they engage us to provide marketing campaigns on their behalf, or if they use our Services to learn more about their customers and to target communications to them accordingly. For example, if a Client runs a query on a list of their customers’ email addresses to determine which subset of that group has visited a resort destination during a major film festival, the matching data set will have shared our inference about certain people, based on the dates and location of prior travel bookings.
· If you call our AnswerPoint service, we will share a recording of your call and any relevant information with our Client, so that they may respond to your inquiry or provide applicable customer service to you.
· We may share your Personal Information for various marketing and advertising activities. For example, we may share Personal Information with business or marketing partners in connection with promotions, events, products, and services that are promoted, managed, supported, or otherwise undertaken with that third party. If appropriate, these parties may engage in direct marketing or behavioral advertising. We may allow our affiliates and other third parties (such as Facebook, ad exchanges, data management platforms, or ad servers) to operate on our Sites and process data for behavioral advertising (see additional information above regarding Targeted Advertising). We may also share Information (sometimes including email addresses, often in hashed format) with advertising partners, as part of the marketing of our properties and services on third party sites. You can read additional information about advertising and your rights and choices under “Cookies, Tracking Technologies and Advertising” and “Your Rights and Choices” below.
· If we determine in good faith, that disclosure is appropriate to comply with the law (or respond to any legal process such as a court order or subpoena, government requests in the U.S. or other countries, or a request related to national security in accordance with applicable laws) we will share Information to the extent we believe necessary.
· In the event of a natural disaster or other circumstances, we will share information as needed to protect the vital interests of guests, property managers, business partners, our employees, and others.
8. COOKIES, TRACKING TECHNOLOGIES AND ADVERTISING
Cookies and Tracking Technologies. We may utilize “cookies”, “tags”, “pixels”, “clear gifs” and other similar tracking technologies on our Sites. A cookie is a text file that is placed on your computer or other mobile device when you access the Sites or the Internet. These technologies allow us or our third-party partners or service providers to collect Information about your interaction with our Sites and advertisements. Examples of such Information may include but are not limited to: demographic Information, browser type, IP address, pages viewed, activity conducted, and timing of your visit. You may at any time opt-out of certain tracking mechanisms through your browser settings. However, disabling such features may prevent you from using certain features or taking full advantage of all of our offerings on our Site.
Different types of cookies are used for different purposes on our Sites. Some cookies may be provided by an external third party to provide additional functionality to our Sites and these are included below. Please see your Rights & Choices for information regarding opt-out rights for cookies and similar technologies.
· Strictly necessary cookies. These are cookies that are essential to fulfil an action requested by you, such as identifying you as being logged in. If you prevent these cookies by adjusting your browser settings we cannot guarantee how our Sites will perform during your visit.
· Performance cookies. These are cookies used to improve our Sites, for example for analytics that let us see how a Site is being used and where to make improvements. These cookies are used to collect Information about how visitors use our Sites. The Information is collected in an anonymous form and includes the number of visitors, where visitors have come from to the Sites and the pages they visited.
· Functionality cookies. These cookies enhance the performance and functionality of our Sites, often as a result of something you’re doing as a user. For instance, we may personalize our content for you or remember your preferences (such as your favorite locations or properties).
· Analytics cookies: These are used for analytics purposes and to improve our Services, such as to analyze the traffic to and on our Services (for example, we can count how many people have looked at a specific page, or see how visitors move around the website when they use it, to distinguish unique visits/visitors to our Services, and what website they visited prior to visiting our Site, and use this information to understand user behaviors and improve the design and functionality of our Services).
Do Not Track Requests. We will automatically collect cookies and other information when you visit our Sites. Due to this automatic collection, we do not currently honor browser based “do not track” requests. For information on how to opt-out of the collection of Information by other tracking devices please see Your Rights and Choices below.
9. SECURITY AND DATA RETENTION
We follow and implement reasonable security measures to safeguard the Personal Information you provide us. However, we sometimes share Personal Information with third parties as noted above, and we do not have control over third parties’ security processes. Please note, we do not warrant perfect security and we do not provide any guarantee that your Personal Information or any other information you provide us will remain secure.
· Retention periods established under applicable law;
· Industry best practices;
· Whether the purpose of processing is reasonably likely to justify further processing;
· Risks to individual privacy in continued processing;
· Applicable data protection impact assessments;
· IT systems design considerations/limitations; and
· The costs associated continued processing, retention, and deletion.
We will review retention periods periodically and may pseudonymize or anonymize data held for longer periods.
10. MARKETING AND PROCESSING RIGHTS AND CHOICES
You have the following choices regarding the Personal Information we process:
Direct Marketing. You have the choice to opt-out of our marketing communications at any time by clicking on the unsubscribe link in promotional emails sent from Rentalz or on behalf of our Clients, and generated by our third-party email provider. If an individual sales representative sends an email specifically to you, there is no unsubscribe link in that email, however, you may notify us by forwarding the email to Info@Rentalz.com and notifying us that you do not wish to be contacted again.
Withdrawing Consent. If you have provided consent to any specific processing of your Personal Information, you may withdraw consent any time, to the extent required by law.
Modify or Delete Data. We will honor all valid requests from an individual to modify or delete their data from our Services. If you wish to make these requests, please send an email to Info@Rentalz.com.
Behavioral/Targeted Advertising: You may opt-out or withdraw your consent to behavioral advertising, which may be defined as “Targeted Advertising” or “Sharing” under various privacy laws. You can limit or opt-out of our processing for behavioral advertising by sending an email to Info@Rentalz.com. In some cases, you may be able to opt-out of Targeted Advertising by submitting requests to third party partners, including for the parties listed below:
Other Processing. You may have the right under applicable law to object to our processing of your Personal Information for certain purposes. You may do so by emailing us at Info@Rentalz.com . Note that we may not be required to cease processing based solely on an objection.
Residents of the EU/UK have certain additional rights in their Personal Information under EU law. Please see Additional Information for EU/UK Residents below.
Residents of California (and others as required by applicable law) may request a list of Personal Information we have disclosed about you to third parties for direct marketing purposes during the preceding calendar year. This request must be written, signed, and mailed to us at 702 S. Colorado Blvd. Suite PHN, Denver, CO 80246.
Under the California Consumer Privacy Act (“CCPA”), the Colorado Privacy Act, and certain other state privacy laws, residents of certain US states may have the following rights, subject to regional requirements, exceptions, and limitations.
Access/Know – Right to request any of following: (1) the categories of Personal Information we have collected, sold/shared, or disclosed for a commercial purpose; (2) the categories of sources from which your Personal Information was collected; (3) the purposes for which we collected or sold/shared your Personal Information; (4) the categories of third parties to whom we have sold/shared your Personal Information, or disclosed it for a business purpose; and (5) the specific pieces of Personal Information we have collected about you.
Portability – Right to request that we provide certain Personal Information in a common, portable format.
Deletion – Right to delete certain Personal Information that we hold about you.
Correction – Right to correct certain Personal Information that we hold about you.
Opt-Out- (Sales, Sharing, Targeted Advertising, Profiling)
– Right to opt-out of the following:
· If we engage in sales of data (as defined by applicable law), you may direct us to stop selling Personal Information.
· If we engage in Targeted Advertising (aka “sharing” of Personal Information or cross-context behavioral advertising,) you may opt-out of such processing.
· If we engage in profiling that has legal or similarly significant effects, you may opt-out of such processing. Please note that the Profiles we create are not used for any purposes resulting in legal or similarly significant effects.
Sensitive Information – You may opt out, withdraw your consent for processing, or otherwise limit our use and disclosure of certain Personal Information deemed “Sensitive” under applicable state laws. For example, we collect and process Financial Data and account log-in credentials, which are deemed Sensitive under the laws of certain states. Where permitted by applicable law, these rights do not apply in cases where we only use Sensitive Personal Information where necessary, or for certain business purposes authorized by applicable law.
– California residents have the right to not to receive discriminatory treatment as a result of your exercise of rights conferred by the CCPA.
List of Direct Marketers
– California residents may request a list of Personal Information we have disclosed about you to third parties for direct marketing purposes during the preceding calendar year.
Remove Minors’ User Content
– Residents of California under the age of 18 can delete or remove posts using the same deletion or removal procedures described above, or otherwise made available through the Services. If you have questions about how to remove your posts or if you would like additional assistance with deletion, contact us using the information below. We will work to delete your information, but we cannot guarantee comprehensive removal of that content or information posted through the Services.
Submission of Requests – You may submit requests to us via email at firstname.lastname@example.org or by calling 833-224-2303. Please note that certain requests will be subject to verification of your identity, as required by applicable laws. If you have any questions or wish to appeal any refusal to take action in response to a rights request, email us at email@example.com.
Categories of Personal Information Disclosed for Business Purposes. For purposes of the CCPA, we have disclosed for “business purposes” in the preceding 12 months the Personal Information categories of Identity Data, Contact Data, General Location Data, Device/Network Data, Transaction Data, Inference Data, User Content, Financial Data and Audio/Visual Data to the following categories of recipients: Service Providers; Affiliates; and Clients.
Categories of Personal Information Sold, Shared, or Disclosed for Commercial Purposes. For purposes of the CCPA, we have “sold” or “shared” in the preceding 12 months the Personal Information categories of Identity Data, Contact Data, Transaction Data and Inference Data to the following categories of recipients: Clients, certain Service Providers (e.g. analytics and advertising partners) and Social Media Platforms.
Categories of Sensitive Personal Information Used or Disclosed. For purposes of CCPA, we may use or disclose the following categories of Sensitive Personal Information (disclosures only to our Affiliates and Service Providers, and to Clients with regard to the Client’s own customers): Financial Data. However, we do not sell or share Sensitive Personal Information, or use it for purposes other than those listed in CCPA section 7027(m).
12. ADDITIONAL INFORMATION FOR EU, UK AND OTHER INTERNATIONAL RESIDENTS
Legal Basis for Processing: All processing (i.e., use) of your Personal Information is based on one of a number of legal conditions. Generally, these will be:
· Your consent (for example, to fulfil your request for information, or for marketing communications);
· The performance of our contract with you (e.g., to process your requested transaction, or to share your Information with third party property owners/managers, or payment processors);
· Compliance with a legal obligation (e.g., where we are required to disclose information to a court or a tax authority); and
· Our legitimate interests, provided these do not override your fundamental rights and freedoms (e.g., where we carry out our own direct marketing to guests or property owners who have entered into transactions with us, subject to your right to opt-out of this at any time).
EU, UK and Certain Other Countries – Data Rights: Subject to applicable law, as a resident of the EU or UK, or certain other countries you may have some or all of the following rights in respect of your Personal Information:
· To obtain a copy of your Personal Information together with information about how and on what basis that Personal Information is processed;
· To rectify inaccurate Personal Information (including the right to have incomplete Personal Information completed);
· To erase your Personal Information (in limited circumstances, where it is no longer necessary in relation to the purposes for which it was collected or processed);
· To restrict processing of your Personal Information in certain circumstances;
· To lodge a complaint with your local supervisory authority (for example, the ICO in the United Kingdom).
In order to exercise any of these rights, please contact us at Info@Rentalz.com. Please note that we may request proof of identity.
13. INTERNATIONAL DATA TRANSFERS
If you are located outside of the United States, you understand that by using any of our Services, you are providing Information to Rentalz and its affiliated companies and processors in the United States, and you are voluntarily transferring your Information to the United States in connection with a contract you are entering in relation to a property, or otherwise based on your consent. This transfer of certain Personal Information to the United States is necessary in order to fulfill a contract for booking with Rentalz or our affiliated companies.
14. DATA CONTROLLER
The controller of Personal Information relating to residents of the UK/EEA/Switzerland is: The Rentalz Company LLC, located at 720 S. Colorado Blvd. Suite PHN, Denver, CO 80246 U.S.A.