1. WHAT DOES THIS POLICY COVER?
2. INFORMATION COLLECTED OR RECEIVED
We collect certain personal information about you as necessary to provide services that you request, to fulfill the terms of a contract between you and us, or to comply with our legal obligations. If you refuse to provide this type of personal information, we may not be able to provide services to you. When you reserve, pay for, or stay in a property through Skye Management.
Contact information. When you reserve or stay in a property through Skye Management, we may collect information such as your first and last name, contact phone number, email address, and other digital contact information. We may also collect names and contact information that you provide about other renters or guests. Payment information. When you make a purchase, we collect your payment information, such as information from your credit card, debit card, or check, and your billing address, to allow us to process payments.
Identity information. To prevent fraud, to comply with the requirements of applicable law, or to meet the requirements of a hotel, resort or community association, we may collect proof of identity or proof of age, such as a government-issued driver’s license, passport, or other identity information in connection with your stay. Other information. We may collect information about your automobile(s) and license plate number(s) in connection with your stay at a property that requires this information for parking permits. We may also collect information about your age and the ages of other guests in connection with your stay at a property that imposes a minimum renter age or requires this information for check-in. We may collect additional personal information in connection with your stay to comply with the requirements of applicable law, or to meet the requirements of a hotel, resort or community association. When we provide rental management or marketing services.
Contact information. When we contract with you to provide rental management or marketing services for your property, we may collect information such as your first and last name; the address of your property; your mailing address, contact phone numbers, email addresses, and other digital contact information; and information concerning any entity you own or manage that is an owner of the property. We may also collect names and contact information of any other owners of the property, owners of an entity that owns the property, or guests or family members who use or stay at the property. Bank account, tax, and identity information. In order to make payments to you, we collect information such as your bank account information, tax identification number, or other information. We may also collect proof of identity, such as a government-issued ID, passport, or other identity information in order to verify your identity or comply with applicable law. We may also collect other types of information from you as required to collect or remit lodging or sales taxes on your behalf, apply for or renew a government license or permit relating to rental management services provided to you, or pay utility or other bills on your behalf.
Other information as required by law. We may collect additional personal information about you as necessary to comply with the requirements of applicable law. When you choose to provide us with additional information.
Information provided during communications with Skye Management. When you communicate with Skye Management in person, or by phone, email, text message, application, or other electronic means of communication, we may collect any information that you choose to provide during the communication.
Other information you choose to provide. We may collect other information you choose to provide to Skye Management, for example when you submit a review, comment or request, interact with a Skye Management social media account, attend a Skye Management event, refer a potential guest or owner, conduct a search, enter a contest, sweepstakes, or promotion, designate a preferred language or currency, or use other aspects of our Services.
We may collect certain information about you from third parties. Each third party that collects or processes your information does so subject to its own privacy policies. We encourage you to review the privacy policies of websites that you visit. Skye Management does not control or oversee the manner in which third parties collect, use, or disclose your information.
Information provided in connection with a booking or stay. If you use a third party to book a stay in a property for which Skye Management provides rental management or marketing services, the third party may send us personal information relating to your stay that you provided to the third party, such as your name, contact information, payment method, the names of other renters or guests, reservation dates, and identity information. We may collect information about you from your friends or family members, for example if a friend or family member includes you as part of their reservation. Third parties who provide services to you in connection with your stay, such as a utility, contractor, service provider, tour operator, concierge, resort or community association, or government official, may send us information about the services you used if permitted or required to do so by applicable law. The type of information we receive varies depending on the type of service that was provided. To the extent allowed by applicable law, we may obtain police or background check information or potential fraud alerts from thirdparty providers of identity verification, criminal background check, or money laundering prevention services.
Information obtained in connection with rental management services. When we agree to provide rental management or marketing services for you, a third party such as a utility provider, government entity, former or current property manager or resort or community association may send us information such as your name, contact information, property address, property rental history, utility account numbers and history, sales or lodging tax license number and remittance history, or local rental permit numbers. Other information we obtain from third parties. We may obtain information from business partners about your use of the Services or services provided by third parties. Such information may include your travel preferences and history, products or services you like, or reviews you submit. We may obtain your name and mailing address or other contact information from third parties such as government agencies, direct mailing service providers, or vendors who compile information from public records. We do not intentionally collect sensitive personal information, such as information about your medical history, political views, religious beliefs, or racial or ethnic origin.
We automatically collect certain information about you when you visit a Skye Management website, use a Skye Management application, or communicate with Skye Management. Information about your site visits. When you visit a Skye Management website, we collect information about your activity on the site. We may track the date and time you accessed the site, the pages you visit and how long you viewed them, your searches for properties, your booking activity (including started, attempted, and abandoned bookings), whether you have followed links to other websites, and your other interactions with the site. Your internet browser may automatically transmit information to us, such as what website you came from.
Device and browser information. We may automatically collect information about the hardware, operating system, browser, and extensions or add-ons you are using, IP address, proxy server, ISP or mobile carrier, device identifier, and any crash data associated with your visit.
3. HOW WE USE YOUR INFORMATION
We use your information in different ways, depending on which Services you use and how you use those Services.
We use information about you to provide Services that you request or to fulfill the terms of a contract between you and us. We use information about you to respond to your inquiries or requests; to communicate with you about reservations and stays; to fulfill contractual or legal requirements relating to your request or the Services you are using (for example, to permit you to stay in a property you have reserved); to provide customer service; to provide rental management or similar services; to detect and prevent fraud or illegal activity; and to make or receive payments to or from you.
To optimize, customize and improve our services and your user experience.
We use information about you and your use of the Services to optimize, customize, and improve our Services, our systems, and your user experience. We may use your information to respond to comments, suggestions, and reviews; to personalize your user experience, including changing displayed properties based on your preferences and search and booking history; and to improve and optimize the performance of our websites or applications. We may use your information to send notifications and offers relating to a stay you have booked. We may use location data to find locations nearest to you and provide driving directions to a property you have booked.
To conduct, measure, and improve our advertising and marketing.
We use information about you to communicate with you about Skye Management and Skye Management Services as permitted by law, including sending advertisements and marketing communications. We may use information about you and your search, browsing, and booking history to send promotional messages and offers that may be of interest to you; to analyze and improve the effectiveness of our advertising and marketing efforts; or to conduct marketing campaigns on third-party websites or social media platforms.
We also use your data to produce aggregated information that does not identify you, such as information about ad impressions served or clicked on.
To comply with our legal and contractual obligations and for security and investigation purposes.
We may use information about you to comply with our legal obligations, such as requirements in some jurisdictions to collect and store certain identity and contact information in connection with a booking or information about your tax identification information in connection with making payments to you. We may also use your personal information to comply with our contractual obligations to you or to certain third parties. We may also use your personal information to enforce the terms of an agreement between us and you or a third party; to enforce the terms of our Terms of Service or other policies; or to resolve disputes with you or another Vacasa customer. We may use your information to conduct security investigations or to conduct or cooperate with investigations related to potential criminal activity. We may use your information to detect and prevent fraud, security incidents, and criminal or harmful activity.
4. HOW WE SHARE OR DISCLOSE YOUR INFORMATION
With third parties in order to fulfill our contractual obligations and/or provide Services. We share information about you to provide Services that you request or to fulfill the terms of a contract between you and us. We need to share this information to adequately perform the terms of the contract between us and you.
We may share information with our local service providers, such as maintenance technicians, contractors, and housekeepers, to allow us to provide services you request and that we are contractually obligated to provide. We might also authorize our local service providers to collect information on our behalf. If you are staying in a property reserved through Skye Management, this information may include your full name, the names of other guests, and your telephone number or email address. If we provide you with rental management services or rental marketing services, this information may include your full name and the names of any other owners or contacts you have designated, your telephone number, your email address, the address of the property we are managing or marketing, and your mailing address.
We might also share your contact information with property owners and service providers to allow them to respond directly to your reviews and questions. We may share your information with third parties who provide services to us in connection with a booking. These third parties may provide services related to payment processing; access to property; fraud prevention, identity verification, and risk assessment; and anti-money laundering compliance. These providers’ access to your information is limited to the information they reasonably require to perform specific tasks on our behalf, and they are contractually bound to use it only for purposes for which it is disclosed.
Service providers may be located inside or outside of Europe. In particular, we use service providers located in Europe, North America, South America, and (with respect to properties located in South Africa), South Africa. Some resorts, community associations, government entities, or other third parties may require us to provide guest information in connection with a specific reservation for a property under their control or jurisdiction. We share information with these third parties to the extent it is legally required or that those parties require us to do so as a condition of the rental. This information may include your full name and age, the names and ages of other guests, your telephone number, your address, your government-issued identification (such as a driver’s license or passport number), and vehicle information such as make, model, and license plate number. In some jurisdictions we are required to disclose guests’ full names, contact information, and transaction information related to a rental stay to the owner of the property. We provide your information to third parties at your direction or request. For example, we will provide your information to a third party if you ask us to do so to facilitate the resolution of a dispute. With third parties in order to offer additional services.
To comply with the law, respond to legal requests, resolve disputes, prevent harm to persons or property, and protect our rights.
We may disclose your information, including your personal information, to a court, law enforcement agency, government agency, or other authorized third party in response to a court order, subpoena, warrant, or other legal process or legal requirement, or if we have a good faith belief that disclosure is reasonably necessary to
investigate, prevent, or take action regarding alleged, suspected, or known illegal activities or any activity that may expose us, you, or any third party on whose behalf we act to liability;
comply with our legal obligations;
comply with legal process and to investigate, respond to, or defend ourselves against any claims or allegations asserted against us;
comply with or respond to an audit conducted by a government agency;
enforce our Terms of Service or the terms of any agreement between us and you;
prevent or mitigate harm to persons or property; or
exercise or protect our rights, the rights of our employees, the rights of third parties on whose behalf we act (such as the owners of properties we manage or market), or the rights of the public.
We may attempt to notify you about a legal request or demand for your personal data, where we reasonably believe that notification is appropriate, except where (a) disclosure is prohibited by applicable law or by the terms of the legal process or court order we receive, (b) where the request is an emergency, or (c) we believe providing notice would be futile, would create or increase a risk of harm to persons or property, or would create or increase a risk, or prevent the detection, of fraud. We may dispute legal demands in instances where we believe a request is overbroad or lacks proper authority. However, we do not undertake to provide notice of every request or challenge any legal demand. With vendors that perform services on our behalf. We may share your information with vendors or other third parties that provide us with services or software. For example, we may provide your contact information to operators of communication or marketing platforms so that we may use their platform software to communicate with you. We might share information with a business partner who is running a joint promotion with us or who provides a product or service in partnership with us. We may disclose information to our outside auditors in connection with their auditing services. These vendors’ access to your information is limited to the information they reasonably require to perform specific tasks on our behalf, and they are contractually bound to use it only for purposes for which it is disclosed.
With social media platforms and advertising publishers.
Where permitted by applicable law, we may use certain personal information about you, such as your email address, to hash and share it with advertising publishers such as Facebook or Google to generate leads or otherwise promote our Services. We carry out these activities based on our legitimate interest in conducting marketing activities to offer you services that may be of interest to you. You may ask us to cease using your email address for these marketing activities by sending a request to your data controller at the address listed in Section 11.
To obtain government permits and to collect and remit taxes.
We may share identifying information regarding your property with a government entity or agency in connection with applying for, obtaining, maintaining, or renewing a required license or permit if required in connection with our provision of rental management services. Such information may include your full name and the full name of all owners, your contact information, the address of the property, your tax identification number, and information relating to rental activity In jurisdictions that impose lodging, hotel, occupancy, sales, or other types of taxes on transient or rental occupancy of property, and where an agreement permits us to collect and remit such taxes on behalf of an owner, we may disclose information to government agencies in connection with the collection and remission of taxes. The information we disclose may include your name and contact information, the property address, the dates of stay and transaction amounts, amount of tax collected or due, the permit or license number for the property, and the owner’s tax identification number(s).
We may aggregate your information.
We may aggregate data about individuals who use the Services, meaning we combine and anonymize this information. We may share this aggregated information with third parties to help describe our business, analyze our marketing efforts, comply with regulations, obtain insights about our business practices, and refine the services we offer, and for other business purposes. When we share aggregated information, we do not share personally identifiable data about individuals.
5. YOUR RIGHTS AND PREFERENCES
Communications from Skye Management or Third Parties.
Transaction-related communications from Skye Management.
You may receive business-related communications from Skye Management relating to a booking you have made or an inquiry about a property. Because these communications are necessary for us to provide you with requested services, you cannot opt out of such communications.
Marketing communications from Skye Management.
You may receive marketing communications from Skye Management as permitted by law. You can register or change your preferences to receive or not receive marketing communications from us by clicking the “unsubscribe” link in the communication you have received or contacting your data controller at the address listed in Section 11. Please allow sufficient time for your preferences to be processed. Even if you opt out of receiving marketing messages, we may still contact you for transactional purposes like confirming or following up on a reservation or home inquiry or asking you to review your stay. If you later opt back into receiving marketing communications from us, we will remove your information from our opt-out databases. Transaction-related communications from third parties.
You may receive business-related communications from a third party, such as a resort, relating to a booking you have made or an inquiry about a property. To the extent these communications are necessary for us to provide you with requested services, you cannot opt out of such communications.
Marketing communications from third parties. You may receive marketing communications from third parties with which Skye Management has contracted or with which Skye Management is running a joint promotion. You may opt-out of disclosure of your personal information to such third parties by sending a request to your data controller at the address listed in Section 11. We do not sell your personal information to nonagent third parties. Therefore, there is no ability or need to opt in to or opt out of such sales. Your rights to access and control your personal information.
In addition to the choices described elsewhere in this document, you may have additional rights concerning the collection, use, and sharing of your data. You may exercise any of the rights described in this section by sending a request to your data controller at the address listed in Section 11.
Update your personal information. You may ask us to correct inaccurate or incomplete personal information about you .
Right to access your personal information. In some jurisdictions, you have the right to obtain a copy of your personal information in our possession. You may also have the rights to request a copy of personal information that you provided to us in machine-readable form, and to request that we transfer this information to another service provider if technically feasible to do so.
Right to object to, withdraw consent to, or limit use of your information. In some jurisdictions, you have the right to ask us to stop using some or all of your personal information for certain purposes if our processing of your information is based on legitimate interests. In such cases, we will no longer use your personal information for such purposes unless: (i) our use is required to establish, exercise, or defend legal claims or (ii) we demonstrate compelling legitimate grounds for our use of the information. If our use of your personal information is based on your consent, you may withdraw your consent at any time by sending a request stating what consent you are withdrawing. Any withdrawal of consent is prospective only (meaning it does not apply to our use of your data before we receive the withdrawal).
In some jurisdictions, you may also have the right to limit the ways we use your personal information, especially if the information is inaccurate or our use of the data is unlawful.
Right to file a complaint with a supervisory authority. You have the right to file complaints about our information processing activities with the relevant data protection authority. If your data controller is Skye Management Europe AG, the supervisory authority for data protection is the Swiss Federal Data Protection and Information Commissioner. If you live in the EEA, you may also file a complaint with your country’s data protection authority.
Data retention and deletion.
We retain your personal information for as long as necessary to perform the contract between us and you and to comply with legal requirements. The length of time we retain your information depends on type of information we have collected, the purpose for which we have collected it and the laws of the applicable jurisdiction(s) (usually the jurisdiction of your residence, the jurisdiction of the property where you have booked a stay or that we are managing, or both).
In general, we retain your personal data as necessary to comply with our legal obligations, such as obligations to retain and report information for tax, auditing, and regulatory compliance purposes. We may also retain some of your personal information as necessary to meet our legitimate business interests, such as to enhance our ability to detect fraud or to assert or defend against an actual or potential legal claim by you or a third party.
If you share information with others in connection with your use of the Services, such as by a writing a review or engaging directly with a third party, your information may continue to be visible to the public or to the third party even after we delete it.
Even after we delete your information, portions of your data may remain in aggregated, anonymized, or tokenized form, but are not associated with personal identifiers. In addition, because we regularly back up our systems, portions of your personal information may continue to reside in backup copies for a period of time after it is deleted from our main systems. Lawful bases to collect, use, and share your personal information.
6. YOUR PRIVACY AND OUR GLOBAL OPERATIONS
California: Your California privacy rights
If you live in California and have an established business relationship with us, you are entitled to ask us for a notice describing what categories of personal customer information Skye Management shares with third parties or corporate affiliates for those third parties’ or corporate affiliates’ direct marketing purposes. That notice will identify the categories of information shared and will include a list of the third parties and affiliates with which it was shared, along with their names and addresses. If you are a California resident and would like a copy of this notice, please submit a written request to: Skye Management
Attn: Legal Department, Privacy Team
By email: email@example.com
Additional privacy rights Depending on the laws of the country or state in which you reside, you may have additional rights concerning our collection, use, and disclosure of your personal information.
7. HOW WE SECURE YOUR INFORMATION
When you place an order or make a booking on our websites, all of your order information, including your credit card number and delivery address, is transmitted using Secure Sockets Layer (SSL) technology. SSL technology causes your browser to encrypt your information before transmitting it to our secure server. SSL technology, an industry standard, is designed to prevent someone other than operators of our websites from capturing and viewing your personal information.
We use industry-standard technical measures to protect our websites and your information, and we monitor for and attempt to prevent security breaches. We update and control access to our systems to protect your information, but we cannot guarantee that your information may not be accessed, disclosed, altered, lost or destroyed by breach of any of our security measures. In the event of a data breach, we will comply with applicable laws relating to notification.
8. LINKS TO THIRD-PARTY SITES
9. OUR SITES AND CHILDREN
Our websites and mobile applications are not created for children. To our knowledge we do not collect information online from children under 18. If you are a parent or guardian and think we have information about your child, please contact your data controller at the address listed in Section 11. To learn more about how to protect your child online, visit the US Federal Trade Commission’s materials on protecting children online by clicking here.
This Revision: May 25, 2018
Previous Revision Date: July 10, 2017
Original Effective Date: January 1, 2009
11. CONTACTING US
By email: firstname.lastname@example.org
Last Updated: May 25, 2018
What are cookies?
A cookie is a small text file that is placed in your browser to allow a website to recognize your browser or device. Cookies are used for many purposes, such as enabling certain site functionality, storing user preferences, permitting analytics, and enabling ad delivery. Cookies can help us understand how visitors use our site, help you navigate between pages efficiently, help remember your preferences for later visits, and generally improve your browsing experience. Cookies can also help ensure that marketing you see online is relevant to you and your interests. A cookie is not spyware or a virus, and it does not give us access to your computer or any information about you personally, other than the data you choose to share with us.
The length of time a cookie will stay on your computer or mobile device depends on whether it is a “session” or “persistent” cookie. A session cookie will only remain on your device until you close your browser. A persistent cookie will remain until it expires or is deleted. Each persistent cookie has an expiration date; some cookies may expire after a few minutes while others may not expire for several years.
What types of cookies does Skye Management use?
When you visit and use a Skye Management website, Skye Management or a third party may place a number of cookies in your browser. Some cookies will only be used if you use certain features or select certain preferences, and some cookies will always be used. Cookies placed by the website you’re visiting (in this case, a Skye Management site) are sometimes called “firstparty cookies,” while cookies placed by other companies are sometimes called “third-party cookies.”
In general, there are four different types of cookies, which are explained below. Skye Management routinely uses all four types of cookies.
Essential Cookies. These first-party cookies are also known as “strictly necessary” cookies, and as the name suggests, they are necessary to allow you to move around the Skye Management site and use its features, such as “Save and View Favorites.”
Analytics Cookies. Also known as “performance cookies,” analytics cookies collect information about visits to our sites and how the services we offer are being used. We use this data to make improvements and report our performance. For example, these cookies collect information about how visitors use our sites, which site the visitor came from, the number of each user’s visits and how long a user stays on the site. We might also use analytics cookies to test new ads, pages, or features to see how users react to them. Analytics cookies are primarily third-party cookies.
Functionality Cookies. Sometimes called “preference cookies,” these first-party cookies allow us to remember information you have entered or choices you have made (such as your username, language, region, and marketing preferences) on our sites, so the next time you visit the site you will not have to set them again. These cookies also allow us to provide a better user experience on our website
Targeting Cookies. Skye Management and our advertising partners or other third-party partners may use these types of cookies, also known as “advertising cookies,” to deliver advertising and track ad performance, and enable advertising networks to deliver ads that may be relevant to you based upon your activities (this is sometimes called “behavioral” or “targeted” advertising) on our sites.
How can you manage and delete cookies?
Most browsers accept cookies automatically. However, you can change the settings in your browser to delete cookies that have already been set and to not accept new cookies. Note that if you set your browser to disable cookies, you may not be able to access certain parts of the Skye Management sites and some services we offer may not work properly or at all.
To learn about managing cookie settings in Google Chrome, click here.
To learn about managing cookie settings in Mozilla Firefox, click here.
To learn about managing cookie settings in Internet Explorer, click here.
To learn about managing cookie settings in Safari , click here.
To learn about managing cookie settings in Opera, click here.
Browsers on mobile devices may have different ways to manage cookie settings.
You can find out more information cookie settings at third-party information sites, such as www.allaboutcookies.org.
Do you use any other user tracking technologies?
Skye Management may use other technology that is standard to the Internet, such as pixel tags, web beacons, and other similar technologies, to track visitors to our sites.
Do Not Track disclosure.