1. Who we are.
For the purpose of applicable data protection legislation, the data controller of your personal data is ECH, LLC at 2055 Trade Center Way, Naples, FL 34109, USA. Our data protection officer may be contacted by emailing firstname.lastname@example.org.
2. What is personal data?
We collect information about you in a range of forms, including personal data. As used in this Policy, “personal data” is defined in the European General Data Protection Regulation of 2018, and includes any information which, either alone or in combination with other information we hold about you, identifies you, including, for example, your name, postal address, email address and telephone number.
3. Why do we need your personal data?
We need certain personal data in order to deliver the Services to you.
4. Your Consent.
5. Types of Information We Collect.
We collect information from you in a variety of ways: when you interact with our Services, when you register, and when you use the Services.
- Member Account. We may collect personal data from you, such as your first and last name, e-mail address, phone number, and password when you create a Member Account or otherwise register as a User of the Services.
- Invitations from Administrators. If you are a User who has been invited to use the Services by an Administrator, your Administrator may provide us with your name and email address in order to facilitate such invitation.
- Location and Payment.
- Precise Location. While the App is in use, it may collect your precise location through the use of GPS on your mobile device and possibly through other signals such as nearby wi-fi access points, or Bluetooth-enabled devices. We may use this information to, for example, determine whether there is housing near you.
- Payment. When you choose to pay for a booking via the Services, we will collect all information necessary to complete the transaction, including your name, credit card information, and billing information. We use the PCI-compliant payment processor(s) Elavon and/or Stripe to process all payments we collect through the Services. ECH does not store your credit card details.
- Additional Voluntary Disclosures by You.
- Contact Us. If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.
- Other Collections. We may also collect personal data at other points in the Services that state that personal data is being collected.
- Automatic Data Collection.
- IP Address. To make our Services 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. We may associate your IP address with your account and your other personal data.
These cookies are essential to provide you with our Services and to enable you to use some of the features. For example, they help the content of the pages you request load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
These cookies allow our Services to remember choices you make when you use our Services, such as remembering your language preferences, remembering your login details and remembering the changes you make to other parts of our Services which you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Services.
Analytics and Performance Cookies
These cookies are used to collect information about traffic to our Services and how users use our Services. The information gathered does not identify any individual visitor. The information is aggregated and anonymous. It includes the number of visitors to our Services, the websites that referred them to our Services, the pages they visited on our Services, what time of day they visited our Services, whether they have visited our Services before, and other similar information. We use this information to help operate our Services more efficiently, to gather broad demographic information and to monitor the level of activity on our Services.
We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Services works. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies
You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html.
You can prevent the use of Google Analytics relating to your use of Services by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GBx
Targeted and advertising cookies
These cookies track your browsing habits to enable us to show advertising which is more likely to be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests. Based on that information, and with our permission, third party advertisers can place cookies to enable them to show ads which may be relevant to your interests while you are on third party websites.
Social Media Cookies
These cookies are used when you share information using a social media sharing button or “like” button on Services or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter or Google+. The social network will record that you have done this.
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings. Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.uk. If you do not accept our cookies, you may experience some inconvenience in your use of our Services. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Services.
6. Use of Your Personal Data.
- General Use. In general, personal data we collect is used to provide the Services to you, enable your use of the Services, respond to requests that you make, or to aid us in serving you better. We use your personal data in the following ways:
- facilitate the creation of and to secure your Member Account;
- to complete Confirmed Bookings you make through the Services;
- identify you as a User in our system;
- provide improved administration of our Services;
- provide the Services you request;
- improve the quality of experience when you interact with our Services;
- send you a welcome e-mail to verify ownership of the e-mail address provided when your Member Account was created;
- send you administrative e-mail notifications, such as security or support and maintenance advisories;
- respond to your inquiries related to employment opportunities at ECH or other requests;
- make telephone calls to you, from time to time, as a part of Member Account creation, fraud protection, or to solicit your feedback;
- send newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing purposes of ECH;
- send mobile application notifications to you; and
- display promotions to you, including promotions relevant to your location.
- User Testimonials. If you send us a testimonial about our Services, we may use and disclose it (including your first name) in our discretion. However, we will obtain your consent prior to posting your full name along with the testimonial.
- Creation of Anonymous Information. We may create Anonymous Information records from personal data by excluding information (such as your name or other identifier) that makes the data personally identifiable to you. We use this Anonymous Information to analyze usage and to enhance our Services and improve Site navigation. We reserve the right to use Anonymous Information for any purpose and disclose Anonymous Information to third parties in our sole discretion. “Anonymous Information” means information that is not associated with or linked to your personal data; Anonymous Information does not, by itself, permit the identification of individual persons.
7. Disclosure of Your personal data.
- Third-Party Service Providers. We may share your personal data with third-party service providers, for example: to Suppliers in connection with your Confirmed Booking of Housing through the Site, directly to Housing Providers in connection with your Confirmed Booking, to otherwise provide you with the Services; to conduct quality assurance testing; to facilitate creation of Member Accounts; and to provide technical support.
- Corporate Customers. If your Member Account is associated with a Corporate Customer, we may share your personal data with such Corporate Customer for billing and administrative purposes. Your personal data may also be shared with any Administrator who has been granted access to your Member Account either by the related Corporate Customer or through your acceptance of an invitation to the Services from such Administrator.
- Third Parties for Marketing. ECH does not disclose personal data to third parties for marketing purposes.
- NOTICE TO CALIFORNIA RESIDENTS – YOUR CALIFORNIA PRIVACY RIGHTS. (AS PROVIDED BY CALIFORNIA CIVIL CODE SECTION 1798.83) A CALIFORNIA RESIDENT WHO HAS PROVIDED PERSONAL INFORMATION TO A BUSINESS WITH WHOM HE/SHE HAS ESTABLISHED A BUSINESS RELATIONSHIP FOR PERSONAL, FAMILY, OR HOUSEHOLD PURPOSES (A “CALIFORNIA CUSTOMER”) MAY REQUEST INFORMATION ABOUT WHETHER THE BUSINESS HAS DISCLOSED PERSONAL INFORMATION TO ANY THIRD PARTIES FOR THE THIRD PARTIES’ DIRECT MARKETING PURPOSES. IN GENERAL, IF THE BUSINESS HAS MADE SUCH A DISCLOSURE OF PERSONAL INFORMATION, UPON RECEIPT OF A REQUEST BY A CALIFORNIA CUSTOMER, THE BUSINESS IS REQUIRED TO PROVIDE A LIST OF ALL THIRD PARTIES TO WHOM PERSONAL INFORMATION WAS DISCLOSED IN THE PRECEDING CALENDAR YEAR, AS WELL AS A LIST OF THE CATEGORIES OF PERSONAL INFORMATION THAT WERE DISCLOSED. CALIFORNIA CUSTOMERS MAY REQUEST FURTHER INFORMATION ABOUT OUR COMPLIANCE WITH THIS LAW BY E-MAILING SUPPORT@TRAVELERSHAVEN.COM. PLEASE NOTE THAT WE ARE REQUIRED TO RESPOND TO ONE REQUEST PER CALIFORNIA CUSTOMER EACH YEAR AND WE ARE NOT REQUIRED TO RESPOND TO REQUESTS MADE BY MEANS OTHER THAN THROUGH THIS E-MAIL ADDRESS.
8. International Transfer.
We will only retain your personal data for two years unless a longer retention period is required or permitted by law (for example for regulatory purposes or receipt of purchase).
10. Sensitive Personal Data.
Subject to the following paragraph, we ask that you not send us, and you not disclose, any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us. We will not actively collect information of this nature
11. Your Rights.
If you wish to exercise any of the following rights, please contact us using the details below. In your request, please make clear: (i) what personal data is concerned; and (ii) which of the rights you would like to enforce. For your protection, we may only implement requests with respect to the personal data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and in any event, within one month of your request. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.
- Access. You may access the information we hold about you at any time via your Member Account, where applicable, or by contacting us directly.
- Amend. You can also contact us to update or correct any inaccuracies in your personal data.
- Move. Your personal data is portable – i.e. you to have the flexibility to move your data to other service providers as you wish.
- Erase and forget. In certain situations, for example when the information we hold about you is no longer relevant or is incorrect, you can request that we erase your data.
ECH is committed to protecting the security of your personal data. We use a variety of industry-standard security technologies and procedures to help protect your personal data from unauthorized access, use, or disclosure. We also require you to enter a password to access your Member Account information. Please do not disclose your Member Account password to unauthorized people. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while ECH uses reasonable efforts to protect your personal data, ECH cannot guarantee its security.
15. Questions; Contacting ECH; Reporting Violations.
2055 Trade Center Way, Naples, FL 34109