Trading Places International Inc.
Effective Date: January 1, 2020
1. California Consumer Privacy Act of 2018
The California Consumer Privacy Act of 2018 (“CCPA”) requires that we provide consumers that reside in California certain information about how we collect, use or disclose your personal information. Under the CCPA, “personal information” is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. It does not include publicly available data as defined by the CCPA.
Categories of Personal Information that We Collect, Use, and Disclose:
The type of personal information we collect, use, and disclose will depend on your interaction or relationship with us. The chart below generally identifies the personal information we collect based on the categories of personal information set forth in the CCPA.
|Categories of personal information as set forth in the CCPA
||Personal information we collect
|Name, Contact Information and other Identifiers: Identifiers such as a real name, alias, address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
|| We may collect information such as your name, address, email address, telephone numbers, date of birth, and IP address. In more limited circumstances, we may collect information such as social security number or tax identification number.
|Customer Records: Paper and electronic customer records containing personal information, such as name, signature, physical characteristics or description, address, telephone number, education, current employment, employment history, social security number, passport number, driver’s license or state identification card number, insurance policy number, bank account number, credit card number, debit card number, or any other financial or payment information, medical information, or health insurance information.
|| We may collect information such as your name, address, email address, telephone numbers, owner number, and credit or debit card information. In more limited circumstances, we may collect information such as social security number and other financial or payment information.
| Protected Classifications: Characteristics of protected classifications under California or federal law such as race, color, sex, age, religion, national origin, disability, citizenship status, and genetic information.
|| We may collect information such as your gender or age.
| Purchase History and Tendencies: Commercial information including records of personal property, products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies.
|| We may collect information such as the products or services you purchased or utilized.
| Biometric Information: Physiological, biological or behavioral characteristics that can be used alone or in combination with each other to establish individual identity, including DNA, imagery of the iris, retina, fingerprint, faceprint, hand, palm, vein patterns, and voice recordings, keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.
|| We may collect voice recordings when we monitor and record telephone calls.
| Usage Data: Internet or other electronic network activity information, including, but not limited to, browsing history, clickstream data, search history, and information regarding a resident’s interaction with an internet website, application, or advertisement.
|| We may collect this information as part of your interaction with our websites or through advertisements.
| Geolocation Data: Precise geographic location information about a particular individual or device.
|| We may collect information such as your postal address, zip code, or the location associated with an IP address or particular device.
|Audio, Video and other Electronic Data: Audio, electronic, visual, thermal, olfactory, or similar information, such as, CCTV footage, photographs, and call recordings and other audio recording (e.g., recorded meetings and webinars).
|| We may collect voice recordings when we monitor and record telephone calls, photos or videos that are tagged or shared with us through social media posts, or audio, video, or images captured in security footage of our resorts.
| Professional or employment-related information: Employment history, qualifications, licensing, disciplinary record.
|| We do not collect this information unless you are a job applicant.
|Education Information: Information about education history or background that is not publicly available personally identifiable information as defined in the federal Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).
|| We do not collect this information.
| Profiles and Inferences: Inferences drawn from any of the information identified above to create a profile reflecting a resident’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.
|| We may collect or derive information such as your preferences, characteristics, predispositions, and behavior based on other information we have about you.
Third-Party Cookies & Similar Technologies:
California Resident Rights:
If you are a California resident, you have certain rights with respect to your personal information as set forth below.
Request to Delete:You may request that we delete personal information we have collected about you, subject to certain exemptions provided by law.
Request to Know: You may request, subject to certain exemptions, that we disclose to you the categories of personal information collected; the categories of sources of personal information; the business or commercial purposes for collecting and selling your personal information; the categories of third parties with whom we have shared your personal information; the categories of personal information that we have disclosed or shared with a third party for a business purpose; the categories of third parties to whom your personal information has been sold and the specific categories of personal information sold to each category of third party; and the specific pieces of personal information that we have collected about you in the prior 12 months.
Request to Opt-out of Our Sale of Your Personal Information: We do not sell your personal information.
Submitting Requests: To make a Request to Delete or a Request to Know, please contact us at 877-973-6725 or email@example.com. Please include your full name, postal address, and email address. If you designate an authorized agent to make a request on your behalf, we require you to provide a written and signed authorization of your agent’s permission to exercise your rights on your behalf as provided for in this section. Please include your full name, postal address, and email address along with your agent’s full name, postal address, email address, and relationship to you.
If we are not able to verify your identity based on this information, we will take additional steps to verify your identity before responding to your request. We will respond to verifiable requests received from California residents or their authorized agents in accordance with the law, which provides certain exemptions for disclosure or deletion. For example, if you make a reservation, we may retain your personal information as permitted by law to provide the service you requested.
These rights do not apply to personal information we collect about job applicants, independent contractors, or our current or former full-time, part-time and temporary employees and other staff, or information we collect when we act as a service provider.
Non-Discrimination: We are not permitted to nor do we discriminate against California residents who exercise their rights under the law.
2. Other California Privacy Rights
Privacy rights under Shine the Light and the CCPA are provided under different legal rules and must be exercised separately.
At this time, we do not respond to browser “do not track” signals, as we await the work of interested stakeholders and others to develop standards for how such signals should be interpreted. Third parties, including our authorized service providers, may collect information about your online activities over time and across different websites, including when you visit our websites.
Information we collect about you
In general. We may collect personal information that can identify you such as your name and email address and other information that does not identify you. When you provide personal information through our website, the information may be sent to servers located in the United States and other countries around the world.
- Information you provide. We may collect and store any personal information you enter on our website or provide to us in some other manner. This includes identifying information, such as your name, address, e-mail address, telephone number and fax telephone number, and, if you transact business with us, financial information such as your payment method (valid credit card number, type, expiration date or other financial information). We also may request information about your interests and activities, your gender and age, and other demographic information.
- Information collected automatically. We automatically collect information from your browser when you visit our website. This information includes your IP address, your browser type and language, access times, the content of any undeleted cookies that your browser previously accepted from us (see "Cookies" below), and the referring website address.
- Cookies. When you visit our website, our authorized service provider may assign to your computer one or more cookies, to facilitate access to our site and to personalize your online experience. Through the use of a cookie, our authorized service provider may automatically collect information about your online activity on our site, such as the web pages you visit, the links you click, and the searches you conduct on our site. Most browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies. If you choose to decline cookies, please note that you may not be able to sign in or use some of the interactive features offered on our website.
- Other Technologies. We may use standard Internet technology, such as web beacons and other similar technologies, to track your use of our site. We also may include web beacons in promotional or other e-mail messages or newsletters to determine whether messages have been opened and acted upon. The information we obtain in this manner enables us to customize the services we offer our website visitors to deliver targeted advertisements and to measure the overall effectiveness of our online advertising, content, programming or other activities.
- Information collected by third-parties. We may allow third-parties, including our authorized service providers, advertising companies, and ad networks, to display advertisements on our site. These companies may use tracking technologies, such as cookies, to collect information about users who view or interact with their advertisements. Our website does not provide any personal information to these third parties. This information allows them to deliver targeted advertisements and gauge their effectiveness. Some of these third-party advertising companies may be advertising networks that are members of the Network Advertising Initiative, which offers a single location to opt out of ad targeting from member companies (www.networkadvertising.org).
We may use Facebook Products (as defined by Facebook, which includes Messenger, Instagram and Audience Network) that enable us to follow the actions of visitors to our websites who are redirected to our websites after clicking on a Facebook advertisement; record the effectiveness of Facebook advertisements for marketing, statistical, and market research purposes; serve targeted advertisements on Facebook that match interests determined by your activity on our websites and deliver ads on other websites within the Facebook Audience Network. For further information on Facebook's data collection and use and about your rights and options to protect your privacy, please refer to Facebook's data protection policies at https://www.facebook.com/about/privacy/. You also can deactivate the Facebook Conversion Tracking Pixel at https://www.facebook.com/settings/?tab=ads#_=_.
We may also use Google Marketing Platform, Google Ad Manager, and Google Display Network for marketing and remarketing purposes and may allow third-parties, including our service providers, advertising companies, and ad networks, to display advertisements on our websites. This technology enables (a) users who have already visited our websites and have shown interest in our products or services to see targeted advertising on websites within the Google Partner Network and (b) us to provide targeted advertising based on user interest. Our websites do not provide any personal information to these third parties. These companies may use tracking technologies, such as cookies, to collect information about users who view or interact with their advertisements. This information allows them to deliver targeted advertisements and gauge their effectiveness. More about Google Marketing Platform and Google Ad Manager may be found at http://support.google.com/dfp_premium/answer/2839090. If you would like to opt out of such ad targeting from Google, please visit the Google Ads settings page at http://www.google.com/settings/ads.
How we use the information we collect
In general. We may use information that we collect about you to:
- process your reservation and perform services that you have requested;
- manage your account and provide you with customer support;
- perform research and analysis about your use of, or interest in, our products, services, or content;
- communicate with you by e-mail, postal mail, telephone and/or mobile devices about products or services that may be of interest to you from us;
- develop and display content and advertising tailored to your interests on our site;
- verify your eligibility and deliver prizes in connection with contests and sweepstakes;
- enforce our terms and conditions;
- manage our business and
- perform functions as otherwise described to you at the time of collection.
Financial information. We may use financial information or payment method to process payment for any purchases made on our website, to protect against or identify possible fraudulent transactions, and otherwise as needed to manage our business.
Job applicants. If your personal information is submitted through our website when applying for a position with our company, the information will be used solely in connection with considering and acting upon your application. We may retain your personal information for a period of time, but only for the purpose of considering your application for current or future available positions. This information may be shared with other MVWC subsidiaries for the purpose of evaluating your qualifications for the particular position or other available positions, as well as with third-party service providers retained by us to collect, maintain and analyze candidate submissions for job postings.
With whom we share your information
We want you to understand when and with whom we may share personal or other information we have collected about you or your activities on our web site or while using our services.
Personal information. We do not share your personal information with others except as indicated below or when we inform you and give you an opportunity to opt out of having your personal information shared. We may share personal information with:
- Authorized service providers: We may share your personal information with our authorized service providers that perform certain services on our behalf. These services may include providing travel services, processing reservations, processing credit card payments, providing resort services, delivering packages, providing customer service and marketing assistance, performing business and sales analysis, supporting our website functionality, and supporting contests, sweepstakes, surveys and other features offered through our website. These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purposes.
- Business partners and accommodation providers. By making reservations or purchasing other products on our website which are provided by third parties (such as travel insurance), you consent to our providing your personal information to these business partners. Sharing this information with our business partners allows them to contact you using the e-mail address or other contact information you provided.
- Public Forums and Other Interactive Features. Please be aware that when you disclose personal information through a chat room, forum, message board, news group or social media link on our websites, the information will become public, so it is important for you to exercise discretion and appropriate caution when deciding to reveal personal information. In addition, when you choose to make a posting on such services, certain personal information may be available for other users to view. We urge you to exercise discretion and caution when deciding to disclose your personal information, or any other information, on the websites or in a social media forum. WE ARE NOT RESPONSIBLE FOR THE USE OF ANY PERSONAL INFORMATION YOU VOLUNTARILY DISCLOSE THROUGH OUR WEBSITES VIA THESE FORUMS, LINKS OR OTHER INTERACTIVE FEATURES. Please note that we reserve the right, but have no obligation, to republish content posted in a chat room, forum, message board or news group (including personal information contained therein). In the event that you encounter any website user who you believe is improperly collecting or using information about you or other users, please contact us at firstname.lastname@example.org.
- Other Situations. We also may disclose your information:
- In response to a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us.
- When we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our company, our users, our employees, or others; to comply with applicable law or cooperate with law enforcement; or to enforce our website terms and conditions or other agreements or policies.
- In connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
Aggregated and non-personal information. We may share aggregated and non-personal information we collect under any of the above circumstances. We may also share it with our affiliated companies and third parties to develop and deliver targeted advertising on our websites and on websites of third parties. We may combine non-personal information we collect with additional non-personal information collected from other sources. We also may share aggregated information with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis. For example, we may tell our resort clients the number of visitors to our website and the most popular resorts, features or services accessed. This information does not contain any personal information and may be used to develop website content and services that we hope you and other users will find of interest and to target content and advertising.
How you can access your information
You can review and update your personal information by contacting us. More information about how to contact us is provided below.
Your choices about collection and use of your information
- You can choose not to provide us with certain information, but that may result in you being unable to use certain features of our website because such information may be required in order for you to make reservations, purchase services; participate in a contest, promotion, survey, or sweepstakes; ask a question; or initiate other transactions on our website.
- At any time you can choose to no longer receive commercial or promotional emails from us. To stop receiving promotional mail or newsletters, please write us at: Trading Place International Customer Relations, 25510 Commercentre Drive, #100, Lake Forest, CA 92630; or e-mail us at email@example.com. Please include your name and address. For electronic promotional communication, this can be accomplished through the unsubscribe link provided in every promotional e-mail message. It may take up to 10 days for us to process an opt-out request. We may send you other types of transactional and relationship e-mail communications, such as service announcements, administrative notices, and surveys, without offering you the opportunity to opt out of receiving them. Please note that opting out of receipt of promotional email communications will only affect future activities or communications from us. If we have already provided your information to a third party (such as an event provider) before you have changed your preferences or updated your information, you may have to change your preferences directly with that third party.
How we protect your personal information
TPI employs security firewalls and network-based intrusion detection monitors to protect your personal data. When you place an order online, your personal data and credit card information are tokenized before being sent over the Internet. This protects your personal data from being stolen or intercepted while being transferred through cyberspace. Your credit card information is never stored on our web servers.
We want you to feel confident using our websites to transact business. However, no system can be completely secure. Therefore, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information, or other communications will always remain secure. Users should also take care with how they handle and disclose their personal information and should avoid sending personal information through insecure email. Please refer to the Federal Trade Commission's website at http://www.ftc.gov/bcp/menus/consumer/data.shtm for information about how to protect yourself against identity theft.
Our website is a general audience site, and we do not knowingly collect personal information from children under the age of 13.
Visiting our websites from outside the United States
No Rights of Third Parties
How to contact us
25510 Commercentre Drive, #100
Lake Forest, CA 92630
E-mail address: firstname.lastname@example.org