Original Effective Date: October 26, 2018
Travel Summit County is the controller and responsible for your personal information (collectively referred to as “Travel Summit County”, “we”, “us” or “our” in this Policy).
This Policy describes how we manages your personal information which we collect from our website www.travelsummitcounty.com, the Travel Summit County app and related applications (collectively, our “Site”), and in the course of providing our online services to you, which include recommendations for travel and travel planning in Summit County, including hotels, travel guides, attractions and experiences (“Services”).
Travel Summit County respects your privacy and is committed to protecting your personal information at all times.
This Policy is provided in a layered format so you can click through to the specific areas set out below.
- PURPOSE OF THIS POLICY AND CHANGES TO IT
- INFORMATION WE COLLECT
- HOW WE COLLECT YOUR PERSONAL INFORMATION
- HOW WE USE YOUR PERSONAL INFORMATION
- DISCLOSURES OF YOUR PERSONAL INFORMATION
- MARKETING COMMUNICATIONS
- YOUR LEGAL RIGHTS (U.S)
- INTENDED USERS OF THE SITE; CHILDREN’S PRIVACY
- RETENTION (U.S)
- SECURITY (U.S)
- EXTERNAL LINKS
- USERS/CUSTOMERS BASED IN THE EU
- CONTACT US
We keep our Policy under regular review. This version was last updated on the data stated at the top of this Policy. We will notify you of any material changes to this Policy.
It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
2. INFORMATION WE COLLECT
When you use the Site or our Services, we collect personal data, or personal information, which means any information about an individual from which that person can be identified (hereafter, “Personal Information”).
Personal Information may include:
Identity Information: including your first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender and photograph.
Contact Information: including your home address, company address, billing address, and email address and telephone numbers.
Transaction Information: including details about payments made by you and other details of products and services you have purchased from us.
Profile Information: including purchases or orders made by you, your interests, preferences, feedback, and information about your past and future planned trips.
Usage Information: including information about how you use our Site and Services.
Special Categories of Data: including information about your health, such as health concerns and physical limitations. For example, if you fill out an RSVP form for an evening event and you inform us of your shellfish allergy.
Technical Information: including the date and time of your visit, the duration of your visit, the type of browser and browser language you use, your Internet Protocol (“IP”) or MAC address, your mobile device ID, the type of computer or other operating device used, the actions you take on the Site (such as pages viewed and links clicked), the websites from which you linked to the Site, and the websites you visit after visiting the Site.
We may also collect information that is derived from your Personal Information but which cannot directly or indirectly reveal your identity. This information is not considered Personal Information in law and is outside the scope of this Policy. However, if we combine or connect aggregated information with your Personal Information so that it can directly or indirectly identify you, we treat the combined information as Personal Information which will be used in accordance with this Policy.
We use different methods to collect information from and about you including through:
Direct interactions: You may give us your Personal Information by filling in forms or by corresponding with us by post, phone, e-mail, Live Chat or otherwise. This includes Personal Information you provide when you:
- fill out and submit forms on our Site, relating to:
- Event RSVPs
- Magazine/brochure requests
- General inquiries
- Direct contact requests to Travel Portland staff/departments
- Credentialed media requests and requests for visual assets
- Request For Proposal submissions
- Partnership applications
- subscribe to our Services or publications.
- request marketing to be sent to you.
- engage with us on Social Media Channels (including LinkedIn, Facebook, Instagram, Twitter and YouTube)
Third parties: We also receive Personal Information about you from various third parties, as set out below:
- Contact and Transaction Information from providers of technical, payment and delivery services, including PayPal and ARES, who are based in the US.
- Technical Information from analytics providers , such as Google based in the US; and
- Technical Information from advertising networks, such as Google AdWords, Google Display Network, and Arrivalist based in the US.
- Membership Contribution Data from other members or users of our website based both inside and outside of the EU.
4. HOW WE USE YOUR PERSONAL INFORMATION
We will only use your Personal Information when the law allows us to. Most commonly, we will use your Personal Information in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you. For example, to:
- manage and facilitate booking enquiries and bookings;
- to allow access to and use of our Site and Services;
- process any request for magazines or other materials;
- notify you about changes to our terms or Policy;
- communicate with you about your use of our Sites and services;
- respond to, or follow up on, your comments and questions and otherwise provide customer service.
Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests, including to:
- mange our relationship with you, which might include asking you to take a survey. This is necessary for us to keep our records updated and to study how customers use our products/services;
- notify you about promotions and special offers. This helps us develop our Services and grow our business;
- administer and protect our business and this Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) to help diagnose problems with the Site. This is necessary for the running of our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise;
- deliver relevant website content, blogs, and advertisements to you and measure or understand the effectiveness of the advertising we serve to you. This is necessary for us to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy;
- use data analytics to improve our website, products/services, marketing, customer relationships and experiences. This helps us define types of customers for our products and services, to keep our Site updated and relevant, to develop our business and to inform our marketing strategy;
- personalise your experience on our Site and deliver relevant content to you on Social Media Channels. This helps us develop our Services and grow our business.
Where we need to comply with a legal obligation. For example, to protect our business, our Site and users of our Site; and to notify you of any legal changes to our terms or this Policy.
Where we have your consent. Will we only use your Special Categories of Data for the specific purpose we have collected for and where you have given us your explicit consent to do so.
We may also use aggregated information such as statistical or demographic data for any purpose, for example, to calculate the percentage of users accessing a specific Site feature.
5. DISCLOSURES OF YOUR PERSONAL INFORMATION
Purchases; travel accommodations. If you purchase a product or service through PayPal or if you book travel accommodations through ARES, you will be sharing your information with PayPal and/or ARES, respectively, and your information is subject to PayPal’s and ARES’ privacy policies. If you book hotel stays, ARES will share your personal information with the applicable hotel.
Third-party service providers. We may share your Personal Information with our third-party service providers who provide services on our behalf, including:
- Distribion Inc, and MailChimp Inc, based in US, who provide us email marketing services;
- Google, Arrivalist Inc, BluConic Inc, and Adara Inc, based in US who provide us with data analytics services;
- Social Media Channels, based both in the US and EU, who provide us with online advertising services.
- Caterers or event planners, based in the US, who may need to be informed of your dietary restrictions in order to cater to your individual needs at Travel Summit County events.
These third-party service providers are not authorized to use your Personal Information in any way other than as described in this Policy and are required to keep your Personal Information confidential. Note this paragraph does not apply to Social Media Channels. If you use Social Media Channel’s sites and services, your information is subject to that site’ privacy policies, and you should read those policies to learn how they use your information.
Merger, acquisition, or sale. We may share or transfer Personal Information to a third parties to whom we may choose to sell, transfer or merge parts of our business or our assests. Alternatively, we may seek to acquire other businesses or merge with them. In this event, we will, if allowed, use reasonable efforts to notify you when your Personal Information is shared with or transferred to any third party by posting such notice on the Site and/or by contacting you via the Personal Information you have provided us, if any.
Required by law. We reserve the right to disclose your Personal Information if we reasonably believe we are required to do so by law, rule, regulation, judicial proceeding, court order, subpoena, or similar legal process; if we reasonably believe disclosure is necessary to protect, establish, or exercise our rights or property, or to defend against legal claims; or if we reasonably believe that disclosure is necessary to protect our other Site users or our employees, property, or business, or to take action regarding illegal activities or suspected fraud.
De-identified information. We may share de-identified, aggregated information with third parties, including advertisers and investors without restriction. For example, we may tell our advertisers the number of visitors our Site; the most popular venues, hotels and activities. This information does not contain any Personal Information and is used by us to develop content and our Services.
Public areas of the Site. The Site contains areas where you can post content that will be viewed by other users of the Site. You should be aware that when you voluntarily disclose Personal Information on these areas for public viewing, the information may be collected, stored, used, and disclosed by other users. Such activities are beyond our control, and we shall have no responsibility for or liability regarding the protection or security of such information. Do not post Personal Information that you want to keep private on these areas of the Site.
6. MARKETING COMMUNICATIONS
Travel Summit County strives to provide valuable information to its partners, customers and other individuals that specifically request such information.
We may use your Identity, Contact, Technical, Usage and Profile Information to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
We will only send you marketing communications by email if you have opted in to receive marketing communications from us.
At any time, you may request that we stop sending you for marketing communications by contacting us at the contact information below or unsubscribing from marketing communications. All of our e-newsletters and marketing e-mails include links in the footer of the e-mail for managing all aspects of your subscription, including the ability to globally unsubscribe from all marketing communications.
Please note that we may continue to send you service communications, relating to your use of the Site, product purchases, booked travel accommodations, or other transactional messages relating to your bookings.
Third party marketing
We will get your express consent before sending third-party direct marketing communications to you. To opt out of receiving third-party marketing communications, you should follow the opt-out links on any marketing message sent to you or by contacting the relevant third party directly.
7. YOUR LEGAL RIGHTS (US)
You can modify and update, or ask us to delete from our databases, Personal Information you have given us by contacting us at the contact information listed at Section 14 below. If you request that we delete or change your Personal Information, we will use commercially-reasonable efforts to remove your existing Personal Information, but see Section 9 below for reasons why we may retain some information.
8. INTENDED USERS OF THE SITE; CHILDREN’S PRIVACY
Our Site and Services are directed to people who are at least the age of 16. Children under age 16 are prohibited from using the Site. We do not and will not knowingly (i) collect or permit submission of Personal Information by anyone under age 16 through the Site; (ii) contact children under age 16 for marketing purposes; or (iii) sell products or services to children under age 16. If we learn that we have received information from a child under age 16, we will delete that information from our files. If you are a parent or legal guardian and you think your child under age 16 has given us information, you can contact us at the information listed below. Also, you can learn more about how to protect children’s privacy online here: www.business.ftc.gov/privacy-and-security/childrens-privacy.
9. RETENTION (US)
We may retain all Personal Information in our databases for as long as is necessary or relevant for our business, unless applicable laws require otherwise. This includes as long as we need it to complete a transaction or to do the things described in this Policy. You can contact us via the contact information below and ask us to remove your information from our databases. Note that even after you ask us to remove your information from our databases, it may be impossible to remove some information, such as information tracked in our web server log files and information that may reside in backup files. This residual information is retained to preserve the integrity of our files. We may also retain Technical Information even after you request that we remove your information from our databases, for use in the aggregate and to analyze and improve the Site. Further, even after you request that we remove your information from our databases, we may retain Personal Information and Automatically-Collected Information to comply with any applicable law, rule, regulation, or guideline; to prevent fraudulent activity; to protect ourselves against liability; and to allow us to enforce our contractual or other rights and to pursue available remedies and limit any damages we may sustain.
10. SECURITY (US)
We use standard security measures to protect against the loss, misuse, and unauthorized access, disclosure, and alteration of Personal Information that is under our control. The standard security measures we take will depend on the type of information collected.
We encourage you to use caution when using the Internet. Please do not send us sensitive information via email as this is not secure. Please notify us if you become aware that your Personal Information is lost, stolen, or used without permission.
Unfortunately, no data storage system or system of transmitting data over the Internet or wireless network can be guaranteed to be 100% secure, and no security system can prevent all security breaches. As a result, we do not and cannot guarantee the security of our servers or any Personal Information provided to us. Any transmission of your information to us is at your own risk.
11. EXTERNAL LINKS
If any part of this Policy is determined to be invalid or unenforceable pursuant to applicable law, then the invalid or unenforceable provision will be deemed superseded by a valid, enforceable provision that most closely matches the intent of the original provision and the remainder of the Policy shall continue in full force and effect.
13. SITE VISITORS / CUSTOMERS IN THE EU
This Section 13 applies only if you are based in the EU.
Your Legal Rights
In certain circumstances you have rights under data protection laws in relation to the Personal Information we hold about you. You have the right to:
- Request access to your Personal Information. This enables you to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it.
- Request correction of your Personal Information. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.
- Request erasure of your Personal Information. This enables you to ask us to delete or remove Personal Information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your Personal Information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing your Personal Information. This enables you to ask us to suspend the processing of your Personal Information in the following scenarios:
- if you want us to establish the information’s accuracy.
- where our use of the information is unlawful but you do not want us to erase it.
- Where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims.
- you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request transfer of your Personal Information to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Right to withdraw consent. Where we are relying on consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
You will not have to pay a fee to access your Personal Information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Travel Summit County is based in the United States. Information we collect from you will be processed by us in the United States. This is not a regulated data transfer for data protection purposes. We will however always protect the privacy and security of your Personal Information and use your Personal Information only as described in this Policy.
By using our Services, you understand that your Personal Information will be transferred to third parties based outside of the European Economic Union (“EEA”) with whom we share your information as described in this Policy.
Whenever we store or transfer your Personal Information outside of the EEA, we will do so in accordance with applicable law and we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use certain service 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 data shared between the Europe and the US. For further details, see European Commission: EU-USPrivacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Information out of the EEA.
We will only retain your Personal Information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, account or reporting requirements, after which we shall delete it. This includes data concerning any dietary restrictions you may have informed us about prior to attending a Travel Summit County event. By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Information) for six years after they cease being customers for regulatory purposes.
We may retain your Personal Information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
We may also need to retain some of your Personal Information indefinitely to support the services we offer. For example, if you have unsubscribed from marketing communications or opted out of certain types of processing (i.e. a suppression list), we would need to retain your unsubscribe or opt-out request indefinitely in order to comply with such request.
Content (such as your photographs, video and notepad) that you have shared publicaly on our Site, or on Social Media Channels that are visible to other users may continue to be visible indefinitely.
In some circumstances you can ask us to delete your data: see your legal rights above for further information.
In some circumstances we will anonymise your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
We have put in place appropriate security measures to prevent your Personal Information from being accidentally 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 data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Right to complain
You have the right to make a complaint at any time to the supervisory authority for data protection issues in your jurisdiction. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority so please contact us in the first instance.
14. CONTACT US
If you have questions regarding our information practices, please contact us.
Travel Summit County
Attn: Marketing & Public Relations
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