We collect, use and are responsible for certain personal information about you. When we do so we are subject to various state and federal laws and we are responsible as “controller” of that personal information for the purposes of those laws.
- Key Terms. It would be helpful to start by explaining some key terms used in this policy:
|We, us, our||Timeshare Rental Pros, LLC|
|Personal information||Any information relating to an identified or identifiable individual|
|Services||The timeshare rental management services provided by Time Share Rental Pros, LLC and other related services provided by it and its affiliates.|
|Site||The website owned by Timeshare Rental Pros, LLC at timesharerentalpros.com.|
|You, your||The person(s) using the Site and/or the Services, and any person(s) for whom such person(s) are acting as an agent with respect to the Site and/or the Services.
- Personal Information We Collect About You. We may collect and use the following personal information that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:
|Categories of Personal Information||Specific Types of Personal Information Collected|
|Identifiers||Your name, address, phone number, email address, account name or other online identifier, IP address, credit card or other payment information, or other similar identifiers|
|Non-Identifying Information||Your browser type, operating system, and site usage information
|Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies|
|Internet or other electronic network activity information||Browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement|
This personal information is required to provide our Services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing Services to you.
- How Your Personal Information is Collected. We collect most of this personal information directly from you—by telephone, text or email and/or via our website. However, we may also collect information:
- From publicly accessible sources (e.g., property records);
- Directly from a third party (e.g., sanctions screening providers, credit reporting agencies, or customer due diligence providers);
- From a third party with your consent (e.g., your bank);
- From cookies on our website; and
- Via our IT systems, including:
- Door entry systems and reception logs;
- Automated monitoring of our websites and other technical systems, such as our computer networks and connections, access control systems, communications systems, email and instant messaging systems; and
- any other relevant systems.
- How and Why We Use Your Personal Information. Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.,:
- To comply with our legal and regulatory obligations;
- For the performance of our contract with you or to take steps at your request before entering into a contract;
- For our legitimate interests or those of a third party; or
- Where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so:
|What we use your personal information for||Our reasons|
|To provide Services to you||For the performance of our contract with you or to take steps at your request before entering into a contract|
|To prevent and detect fraud against you or Timeshare Rental Pros, LLC||For our legitimate interests or those of a third party, i.e. to minimize fraud that could be damaging for us and for you|
|Conducting checks to identify our customers and verify their identity.
Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety regulation or rules issued by our professional regulator
|To comply with our legal and regulatory obligations|
|Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies||To comply with our legal and regulatory obligations|
|Ensuring business policies are adhered to, e.g. policies covering security and internet use||For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you|
|Operational reasons, such as improving efficiency, training and quality control||For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price|
|Ensuring the confidentiality of commercially sensitive information||For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information
To comply with our legal and regulatory obligations
|Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures||For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price|
|Preventing unauthorized access and modifications to systems||For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you
To comply with our legal and regulatory obligations
|Updating and enhancing customer records||For the performance of our contract with you or to take steps at your request before entering into a contract
To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products
|Statutory returns||To comply with our legal and regulatory obligations|
|Ensuring safe working practices, staff administration and assessments||To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
|Marketing our services and those of selected third parties to:
||For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers|
|Credit reference checks via external credit reference agencies||For our legitimate interests or those of a third party, i.e. to ensure our customers are likely to be able to pay for our products and services|
|External audits and quality checks||For our legitimate interests or a those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards
To comply with our legal and regulatory obligations
The above table does not apply to special category personal information, which we will only process with your explicit consent.
- Promotional Communications. We may use your personal information to send you updates (by email, text message, telephone or post) about our Services or those of our affiliates, including exclusive offers, promotions or new Services.
We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal information with the utmost respect and never sell OR share it with other organizations outside Timeshare Rental Pros, LLC and its affiliates for marketing purposes.
You have the right to opt-out of receiving promotional communications at any time by:
- Contacting us via email at firstname.lastname@example.org, by phone at (855) 377-6817, or by mail at 201 W. Big Beaver Road Suite 500 Troy, MI 48084; or
- Using the “unsubscribe” link in emails or “STOP” number in texts.
We may ask you to confirm or update your marketing preferences if you instruct us to provide further Services in the future, or if there are changes in the law, regulation, or the structure of our business.
- Who We Share Your Personal Information With. We routinely share personal information with:
- Our affiliates, including companies within the Timeshare Rental Pros, LLC group;
- Service providers, we use to help deliver our Services to you, such as payment service providers, warehouses and delivery companies;
- Other third parties we use to help us run our business, such as marketing agencies or website hosts;
- Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers;
- Credit reporting agencies;
- Our insurers and brokers; and
- Our bank(s).
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g. in relation to ISO accreditation and the audit of our accounts.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
We will not share your personal information with any other third party.
- Personal Information We Sold or Disclosed for a Business Purpose. In the preceding 12 months, we have disclosed for a business purpose to one or more third parties the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:
- Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers);
- Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information;
- Characteristics of protected classifications under California or federal law;
- Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);
- Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement);
- Professional or employment-related information; and
- Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
- Where Your Personal Information is Held. Information may be held at our offices and those of our affiliates, third party agencies, service providers, representatives and agents as described above (see above: “Who We Share Your Personal Information with”).
- How Long Your Personal Information Will Be Kept. We will keep your personal information while you have an account with us or while we are providing Services to you. Thereafter, we will keep your personal information for as long as is necessary:
- To respond to any questions, complaints or claims made by you or on your behalf;
- To show that we treated you fairly; or
- To keep records required by law.
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.
When it is no longer necessary to retain your personal information, we will delete or anonymize it.
- Your Rights Under the CCPA. You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:
|Disclosure of Personal Information We Collect About You||You have the right to know:
|Personal Information Sold or Used for a Business Purpose||In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know:
The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and
The categories of personal information that we disclosed about you for a business purpose.
You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the sale or disclosure of your personal information. If you exercise your right to opt-out of the sale or disclosure of your personal information, we will refrain from selling your personal information, unless you subsequently provide express authorization for the sale of your personal information.
|Right to Deletion||Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:
|Protection Against Discrimination||You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:
Please note that we may charge a different price or rate or provide a different level or quality of Services to you, if that difference is reasonably related to the value provided to our business by your personal information.
- Keeping Your Personal Information Secure. We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
- Contact us via email at email@example.com, by phone at (855) 377-6817, or by mail at 201 W. Big Beaver Road Suite 500 Troy, MI 48084;
Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.
If you choose to contact directly by website, email, phone, or in writing, you will need to provide us with:
- Enough information to identify you (e.g., your full name, address and customer or matter reference number));
- Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
- A description of what right you want to exercise and the information to which your request relates.
We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.
Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.
- Changes to This Privacy Notice. This privacy notice was published on November 17, 2021 and last updated on November 17, 2021.
We may change this privacy notice from time to time–when we do, we will inform you via a notice posted on our website.
- Do You Need Extra Help? If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).