Aspen Signature Properties, LLC Privacy Policy
Updated and Effective as of June 26, 2024
This Privacy Policy describes our practices regarding the collection, use, disclosure, storage, and other processing of information collected by Aspen Signature Properties, LLC, (“Company,” “we” or “us”) through any website, application, feature, widget or other online service that is owned or controlled by us (collectively, the “Sites”), that posts a link to this Privacy Policy, and by Company offline.
Please review this Privacy Policy carefully. By accessing, using, or otherwise interacting with any part of our Sites, you agree to be bound by the terms of this Policy and the applicable Terms of Use which govern your use of any Site. IF YOU DO NOT AGREE TO THE TERMS OF THIS POLICY AND THE APPLICABLE TERMS OF USE, DO NOT ACCESS OR USE THE SITES OR PROVIDE PERSONAL DATA TO US.
We may also provide additional disclosures or information about the data processing practices of certain features or services when you provide your information to us. These disclosures may supplement or clarify our privacy practices or provide you with additional choices about how we process your data.
TABLE OF CONTENTS
● THE INFORMATION WE COLLECT AND HOW WE COLLECT IT
- Information You Provide Us Directly
- Information We Collect Automatically
- Information Third Parties Provide About You
● OUR USE OF INFORMATION COLLECTED THROUGH THE SITES
● HOW WE SHARE INFORMATION WITH THIRD PARTIES
● THIRD-PARTY ADVERTISING AND ANALYTICS COMPANIES AND SIMILAR THIRD PARTIES ● CHANGING YOUR INFORMATION
● ADDITIONAL CHOICES ABOUT HOW WE USE YOUR INFORMATION
● DATA SECURITY
● CONSENT TO TRANSFER
● GENERAL AUDIENCE SITE
● THIRD PARTY LINKS AND CONTENT
● CHANGES TO THIS PRIVACY POLICY
● CONTACT US
● NOTICE TO NEVADA RESIDENTS
THE INFORMATION WE COLLECT AND HOW WE COLLECT IT
We collect information from you directly, automatically when you visit the Sites, and sometimes from third parties. Some of this information may be considered “personal information” or “personal data,” under various applicable laws. We consider information that identifies you as a specific, identified individual to be personal information and we treat additional information, including IP addresses and cookie identifiers, as “personal information” where required by applicable law. And if we combine information we consider to be non-personal with personal information, we will treat that combined information as personal information under this Privacy Policy. Note that we may de-identify or pseudonymize personal information so that it is non-personal. We maintain and use de-identified data without attempting to re-identify it, except where permitted by applicable law, such as to determine whether our de-identification processes satisfy legal requirements. We will treat such information as non-personal to the fullest extent allowed by applicable law.
Information You Provide Us Directly
We may ask you to provide information when you use and/or interact with the Sites, including information you may input to post reviews on the Sites. We may also collect information from you when you otherwise communicate with us.
User Content Submissions. The Sites may provide you the opportunity to submit information to us, through interactive features, and through other communication functionality (“Submission Features“). You may choose, through such features or otherwise, to submit or post “User Submissions” (which means any and all information and content that you submit or post to the Sites, including, without limitation, photos, audio, video, messages, text, files, reviews, or other content you provide us and as further described in our Terms of Use. Your User Submissions may also be subject to additional terms, which we may ask you to agree to when you submit a review. Some features, such as user reviews, may be operated by a third party and your postings also may be subject to the third party’s privacy policy and terms of use.
Please note that certain information, such as your name, may be publicly displayed on the Sites along with your User Submissions. Your use of any Submissions Feature is subject to our Terms of Use, including without limitation the “User Submissions” section. Note that anything you submit through a public-facing Submission Feature may be made public – others will have access to your User Submission and may use it or share it with third parties. We are not responsible for the actions of third parties and the use of your data and other User Submissions by such third parties is not subject to the protections of this Privacy Policy.
Social Networking Features. Functionality on the Sites may permit interactions between the Sites and a third-party service such as Facebook or Instagram (“Social Networking Features”). Examples of Social Networking Features include enabling you to “like” or “share” content from the Sites or to “like” or “share” our content on a third-party service; to automatically or selectively show your social media posts on the Sites; and to otherwise connect the Sites to a third-party service. If you choose to share content or to otherwise post information through the Sites to a third-party service, or vice versa, that information may be publicly displayed. Similarly, if you post information on a third-party service that references us (for example, by using a hashtag associated with us in your post), your post may be published on the Sites or otherwise in accordance with the terms of that third party.
Also, both we and the third party may have access to certain information about you and your use of the Sites and the third-party service. In addition, the third party service may set their own cookies and collect data about your use of the Sites, including your IP address or other device identifiers, and which pages you visit on the Sites. These third party platforms may be able to collect certain data on your visits to the Sites regardless of whether or not you affirmatively interact with the feature and whether or not you are logged into (or have) an account with the third party platform. If you are logged out or do not have an account and visit a page with a social plug-in, your browser sends a more limited set of information. Like other sites, the third party platform will receive data about the webpage you are visiting, the date and time of your visit, and other browser-related information. They may use that information to help them improve their products or for other purposes set forth in their privacy policy. We may also receive data about you if other users of social media give us access to their profiles and you are one of their connections or “friends.”
The data we collect in connection with Social Networking Features is subject to this Privacy Policy. The data collected and stored by the third party remains subject to the third party’s privacy practices, including whether the third party continues to share data with us, the types of data shared, and your choices with regard to what is visible to others on that third-party service.
If you submit User Submissions or use Social Networking Features, we may publish that information or content online or offline, including in connection with our advertising, marketing, publicity, and promotional activities, as further described in our Terms of Use or additional terms that you may agree to before submitting a User Submission.
Contests & Promotions. We may offer contests, and other promotions (any, a “Promotion”) that may require registration. By participating in a Promotion, you are agreeing to the provisions, conditions, or official rules that govern that Promotion, which may contain specific requirements of you (including, except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice, likeness or other indicia of persona in advertising or marketing materials). If you choose to enter a Promotion, personal data may be disclosed to third parties (including, without limitation, a co-sponsor) or the public in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion’s terms or official rules (such as on a winners list).
Chat Boxes. We may provide a “Live Chat” feature for you to communicate with us. When you participate in our Live Chat feature, Company can record and use your communications and the information you provide to assist you during the Live Chat session, to provide customer service, improve our products and services, and for marketing. If you do not consent, please do not continue with chat assistance.
Information We Collect Automatically
We and third-party business partners (such as analytics, advertising companies, and similar third parties) may use a variety of technologies that automatically or passively collect certain information whenever you visit any Site or otherwise interact with us or our content (“Usage Information”). Usage Information may include the hardware model, browser, and operating system you are using, the URL or advertisement that referred you to the Site you are visiting, all of the areas within the Sites that you visit, your time zone, and mobile network (if applicable), among other information. In addition, we automatically collect your IP address or other unique identifier (“Device Identifier”) for any computer, mobile phone, or other device you use to access our Sites. In some cases, we may directly collect location information through your device. You may be able to turn off the collection of location information through the settings on your device.
The methods that may be used to collect Usage Information include the following:
• Cookies and Local Storage. Cookies and local storage are data files placed within a browser on a device when it is used to visit the Sites. Certain web browsers and browser add-ons may provide additional local data storage mechanisms. Cookies and local storage can be used for a variety of purposes, including to store a unique identifier for your device that recognizes your device as you visit the Sites or other web sites or online services and to remember your preferences. Most browsers provide you with the ability to disable or decline cookies and local storage. You will need to check your browser’s settings for further information. If you choose to disable cookies or to adjust your privacy settings on your device, some features of the Sites may not function properly. For more information about cookies and managing cookies generally, visit http://www.allaboutcookies.org. • Web Tags. Small graphic images or other web programming code called web beacons (also known as “1×1 GIFs” or “clear GIFs”), may be included in our web pages and e-mail messages. Web tags or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Sites, to monitor how users navigate the Sites, to count how many e-mails that were sent were actually opened or to count how many particular videos or links were actually viewed.
• Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Sites, such as the links you click on. The code is temporarily downloaded onto your device from our server or a third-party service provider or business partner, is active only while you are connected to a website, and is deactivated or deleted thereafter.
● Data Collection from Mobile Devices. We may use embedded scripts and similar tools to collect data from mobile devices such as the hardware model, operating system and version, identification numbers assigned to your mobile device, such as the ID for Advertising (IDFA) on Apple devices, and the Advertising ID on Android devices, mobile network information, and website usage behavior. In addition, we may use a variety of other technologies that collect similar device and device interaction information for security, fraud detection, and maintenance purposes.
In addition, we may use these and a variety of other technologies that collect Usage Information and similar information for security and fraud detection purposes and to enforce our intellectual property rights.
Information Third Parties Provide About You
We may receive information about you from third parties, including business partners. For example, if you are on another website and you agree to receive information from Company, that site will forward your information to us so that we may contact you. We may also receive information about you from a third party through our referral program which allows certain third parties to refer property owners to us for vacation rental management services. We use the information we receive from third parties to better provide you with information and products, to tailor our content and the offers we show to you, and for other business purposes.
We may also supplement the data we collect with outside records from third parties, such as public databases, publicly available social media pages, and third parties who enhance the data we have about you, in order to provide you with information, services or products you have requested, to tailor content, to offer you opportunities to purchase products or services that we believe may be of interest to you, and for other purposes.
Send-to-a-Friend Features. We may make available on the Sites a “send-to-a-friend,” “refer a friend,” “wishlist” or similar function that permits you to send Site content directly to a third party through the Sites. If you send a friend a communication using such functionality, the information you provide about your friend (e.g., name and e-mail address) is used to facilitate the communication and is not used for any other marketing purpose unless we obtain consent from that person. If you disclose any personal data relating to other people, you represent that you have the authority to do so and to permit us to use the data in accordance with this Privacy Policy.
OUR USE OF INFORMATION COLLECTED THROUGH THE SITES
Company may use information collected through the Sites, including Usage Information and personal information, to:
1. provide our Sites, including to allow you to participate in features we offer or to provide related services;
2. provide you with information, products, or services that you have requested, to contact you regarding any problems with your bookings or account, and to respond to your inquiries related to your transactions or use of the Sites;
3. process your transactions, including processing payments you submit in connection with your purchases;
4. recognize you across the Sites and across devices;
5. tailor content recommendations, advertising, promotions, and offers we display to you, both on the Sites and elsewhere online;
6. process referral payments made to you as part of our referral program;
7. investigate and prevent fraudulent transactions and other illegal activities or activities that violate our policies;
8. improve the Sites or our services and for internal business purposes;
9. contact you with regard to your use of the Sites and, in our discretion, changes to the Sites’ policies; and
10. for purposes disclosed at the time you provide your personal information or otherwise with your consent.
HOW WE SHARE INFORMATION WITH THIRD PARTIES
Company may share non-personal information, which may include Usage Information or information that has been hashed or otherwise de-identified or pseudonymized, with third parties in our discretion. In addition, Company may share this information we have collected about you as allowed by law and as disclosed at the time you provide your information or otherwise with your consent, as described in this Privacy Policy and in the following circumstances:
Rental Property Owners
When you book a rental property with us, we may share certain personal information relating to your booking with the owner of the property.
Company Affiliates
When Company collects information through the Sites, it may be accessible to Company affiliates. The information will be used for business, operational and marketing purposes.
When You Direct That We Share Your Information
We may share information when you direct us to do so. For example, you may engage with a social media service or other third party application or feature, through which information about you is shared. Please note that we are not responsible for the privacy practices of third parties. If you later decide that you no longer want to receive communications from a third party, you will need to contact that third party directly.
Contests and Promotions
As noted above, if you choose to enter a Promotion, your personal information may be disclosed to third parties or the public in connection with the administration of such Promotion, including in connection with winner selection, prize fulfillment, as required by law, or as permitted by the Promotion’s terms or official rules (such as on a winners’ list).
Third Parties Providing Services on Our Behalf
We may share information with third-party service providers or allow those third parties to collect information about you, to enable them to perform services on our behalf, such as website hosting, conducting website and app usage analytics, sending email, text, or other communications, fulfilling orders, fraud prevention, providing marketing assistance and data analysis, and other services.
Administrative and Legal Reasons
Products and services we promote and sell may be subject to federal, state or other legal regulation and complying with those legal regulations may include providing access to your
personal information, including transaction history. We may transfer and disclose user information to third parties: (i) in the event we are required to comply with a legal obligation or regulation, respond to subpoenas or other legal process or if we believe in good faith that the law requires it; (ii) at the request of governmental authorities conducting an investigation; or (iii) to protect and/or defend the Terms of Use, or other policies applicable to the Sites or our services; (iv) to respond to an emergency; or (v) otherwise to protect the personal safety, rights, property or security of Company, our customers, or a third party. We may also use Device Identifiers, including IP addresses, to identify users, and may do so in cooperation with copyright owners, Internet service providers, wireless service providers or law enforcement agencies in our discretion.
Business Transfers
In the event Company goes through a transition, Company reserves the right to disclose and transfer all information related to the Sites (including, without limitation, during the course of any due diligence process): (i) to a subsequent owner, co-owner or operator of the Sites or applicable database; or (ii) in connection with a corporate merger, consolidation, restructuring, bankruptcy, the sale of certain of Company’s ownership interests, assets, or both, or other company change. By providing your information, you understand and agree that we may transfer such information to the acquiring entity without your further consent.
THIRD-PARTY ADVERTISING AND ANALYTICS COMPANIES AND SIMILAR THIRD PARTIES Except where specifically prohibited by law, Company works with third party business partners (such as network advertisers, ad agencies, analytics providers, and other advertising partners) to serve our ads online, to serve third party ads on the Sites, and to provide us with information regarding the use of the Sites and the effectiveness of our advertisements. These third parties may set and access their own tracking technologies on your device (including cookies and web beacons), and they may otherwise collect or have access to Usage Information and other information about you, some of which may be personal information under various state laws. Some of these parties may collect personal information over time when you visit the Sites or other online websites and services. We may use information, typically information that has been hashed or otherwise de-identified (including hashed email addresses) and Usage Information, to make inferences about you and provide offers and content you may be interested in and serve you more relevant advertising, and share it with third party advertising companies, analytics providers and other third parties for the purpose of serving you more relevant ads on and off the Sites.
We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Sites and report on activities and trends. This service may also collect information regarding the use of other websites, apps, and online services. You can learn about Google’s practices by going to https://policies.google.com/privacy/google-partners, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout
We may use a variety of companies to serve our advertisements. Some of these companies are members of the Network Advertising Initiative (“NAI”) or the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising and you may want to visit the following webpages, which provide “opt-out” mechanisms for participating companies: https://optout.networkadvertising.org and https://optout.aboutads.info.
You can opt-out from interest based advertising on your mobile device through your mobile device settings. Please note opting out through these mechanisms does not opt you out of being served advertising and you will continue to receive generic ads while online.
Mobile devices may contain settings that allow you to disable tracking advertising and/or analytics. In addition, the digital advertising industry has provided the ability for mobile users to register at https://youradchoices.com/appchoices for their intent not to receive targeted advertising.
Please note that opting out through these mechanisms does not opt you out of being served advertising, and that you will continue to receive generic ads while online.
CHANGING YOUR INFORMATION
You are responsible for maintaining the accuracy of the information you submit to us. Certain Sites may allow you to correct or update certain personal information you have provided. Note that when you edit your personal information, information that you remove may persist internally for Company’s administrative purposes or within backup media.
ADDITIONAL CHOICES ABOUT HOW WE USE YOUR INFORMATION
Company offers you the following choices with regard to the information collected through the Sites:
● Marketing Emails. You may opt out of receiving marketing e-mails by following the opt-out instructions provided to you in those e-mails. Please note that we reserve the right to send you certain communications relating to your account or use of the Sites or our services, such as administrative and services announcements. These transactional account messages may be unaffected if you choose to opt out from marketing e-mails.
DATA SECURITY
Although Company takes commercially reasonable steps designed to help prevent the loss and unauthorized access of your information, no data transmission, wireless transmission, or storage of information can be guaranteed to be 100% secure. As a result, we cannot ensure or warrant the security of any information we collect. You use the Sites and provide us with information at your own initiative and risk.
CONSENT TO TRANSFER
Company is located in the United States. Like most websites and businesses, our Sites may be accessed by an international audience. By visiting our Sites, and/or providing us with any data,
you specifically consent to our collection, processing, use, and storage of your personal information as discussed herein, outside your resident jurisdiction, including in countries where data protection standards may differ from those in the country where you reside. Our third party service providers may also be located outside of your jurisdiction. As a result, this information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to laws in those jurisdictions.
GENERAL AUDIENCE SITE
The Sites are intended for a general audience and are not intended for use by or targeted to children younger than the age of 18. We do not knowingly collect personal data from children younger than the age of 18.
DO NOT TRACK
Some browsers incorporate a ‘Do Not Track’ (DNT) feature that, when turned on, signals to websites and online services that you do not wish to be tracked. Because there is not yet an accepted standard for how to respond to browser DNT signals, we do not currently respond to them.
THIRD PARTY LINKS AND CONTENT
The Sites may contain links to other web sites that Company does not control, and advertising and other content hosted and served by third parties. The third parties whose content appears on the Sites may collect information about you through the use of cookies and web beacons, may independently collect or solicit personal information, and may have the ability to track your use of their sites and services. Likewise, our content may be included on third parties’ web pages and web sites that are not associated with Company and over which we have no control. We may collect Usage Information through Company content appearing on third party sites. Company is not responsible for the privacy practices of any third party.
CHANGES TO THIS PRIVACY POLICY
To the extent allowed by applicable law, Company may modify this Privacy Policy at any time effective upon its posting on our websites. We may also provide notice to you in other ways such as through contact information you provided. As this Privacy Policy may be modified from time-to-time, you should check this Privacy Policy frequently for any such changes. Any changes will be effective immediately upon the posting of the revised Privacy Policy unless otherwise specified, and your continued business relationship with us, or use of our Sites after the changes are posted (or such other act as specified in the revised Privacy Policy) constitutes your acceptance of any changes to the fullest extent allowed by applicable law. However, we will provide notice and obtain your consent (opt-in or opt-out) if required.
CONTACT US
If you have any questions about this Privacy Policy, please contact us at: Aspen Signature Properties, LLC, info@aspensignatureproperties.com
NOTICE TO NEVADA RESIDENTS
Company does not currently sell your covered information as those terms are defined under applicable Nevada law. However, you may submit an opt-out request and we will honor that request as required by Nevada law if Company engages in such a sale in the future. If you are a Nevada resident and would like to opt-out of the sale of your covered information, please submit your request to info@aspensignatureproperties.com. Your request must include your full name, street address, city, state, and zip code. Please contact us from the email address you have used to interact with us, or else provide us with that email address in your Nevada Opt-Out request email. We may contact you via such email address as needed regarding this request. You may also be required to take reasonable steps as we determine from time to time in order to verify your identity and/or the authenticity of the request. We will respond to your request within sixty (60) days either confirming that your request has been processed or indicating that we need an additional thirty (30) days to complete the request.