Last updated May 25, 2018
c) Notice. Personally Identifiable Information (“PII”) is information that identifies you or could reasonably be used to identify you personally (such as your real name, address, phone number or email address). For example, when you create an account with us, your account information is stored on the Service’s server. When you provide PII to Company via the Service, we will tell you who is collecting the information, how and why the information is being collected, and how it may be used. We will give you options regarding our use of your PII, including whether we can share it with outside companies.
2) Collection of Information
a) Submission. Company collects PII in order to enhance the Service for Users. We may collect your name, email address, billing information, mobile telephone number and other information reasonably requested from time to time. You voluntarily submit information to Company when you (1) register for and/or interact with the Service (via the internet, mobile phone, tablet or otherwise) which includes your use of the Service at one of our hotel or multi-unit dwelling partners’ locations (via web, mobile application or in-room tablet) , (2) access or view the website with or without registering for the Service, or (3) suggest (via emails, chats, bulletin boards, posting comments, etc.) how we can improve the Service. With your permission, we may also access other PII on your device, such as your contacts or other stored information, in order to provide (or to enable our hotel or multi-unit dwelling partners and other third party service providers to provide) services to you during your stay. If made available by Company, and if authorized by you by allowing you to “register” for the Service via Facebook or other Social Networking Site (“SNS”), we may also access profile and other information from Facebook or other SNS. Our systems may associate this PII with your activities in the course of providing the Service to you (such as pages you view or things you click on or search for). We may record or store archives of any communications you have within or in connection with Service on Company’s servers to protect our users, as well as, Company’s rights in connection with the Service. You acknowledge, agree and consent to the collection and storage of all such information you submit to and within the Service.
b) Third Party Sources. We may collect PII from reputable third parties and sources including, without limitation, public databases.
c) Non-Personally Identifiable Information. When your computer, mobile phone or tablet device contacts our web servers (for example, when you visit the Site, use the mobile or tablet application or view an HTML e-mail), our web servers automatically collect Site usage information. Site usage information is non-identifying information that describes how our visitors use and navigate our Site. It can include the number and frequency of visitors to each web page and the length of their stays, browser type, referrer data that identifies the web page visited prior and subsequent to visiting our Site, and IP addresses (see below for more information on IP addresses). We also may determine the applicable technology available in order to serve you the most appropriate version of a web page, e-mail or similar service. This information is used to analyze and improve the Site.
e) Use of Web Beacons. Our web pages or e-mail messages may contain a small graphic image called a web beacon, which is sometimes also called a “clear gif”, that allows us to monitor and collect certain limited information about our Users, such as the type of browser requesting the web beacon, the IP address of the computer that the web beacon is sent to and the time the web beacon was viewed. Web beacons can be very small or invisible to the user, but, in general, any electronic image viewed as part of a web page or e-mail, including HTML based content, can act as a web beacon. We may use web beacons to count visitors to Site or to monitor how our users navigate the Site, and we may include web beacons in e-mail messages in order to count how many messages we sent were actually opened or acted upon. We may also use web beacons to compile aggregate statistics about the Service and our marketing campaigns.
f) Site Visitors. We may collect certain information about Site visitors for site maintenance, optimization, security and other legally permissible purposes. Such information may include, without limitation, visitors' IP addresses, browser types, dates, times, and duration of visits, and particular pages viewed. An IP address is a number that is assigned to your computer or network when you are linked to the Internet. When you request pages from our Site, our servers log your IP address. We may use IP address for a number of purposes, such as system administration, to report aggregate information to our business partners or to audit the use of the Site. We may associate your IP address with the PII you provide.
g) Manual. We may collect PII from consumers in manual format or off-line, such as a post card or subscription form.
h) Mobile Devices. If you use the Service on your mobile phone or other mobile device (including tablet devices such as an iPad or an Android based Tablet), we may collect mobile device identifiers, including MAC addresses and IP addresses. If we use that information, we will do so to create an identifier that is similar to an account number. We may also collect the name you have associated with your device, device type, telephone number, country and any other information you choose to provide such as a user name, character name, your location or email address. You agree that we may access your contacts information on your device to enable you to invite friends to join you in the Service.
Special Notice Regarding Minors
Company respects the privacy of children of all ages. Company particularly recognizes the sensitivity of personal information concerning children under the age of 13 and therefore provides this special notice to parents and guardians regarding the collection and use of information collected from children in this age group. The Service is not directed toward young children. If you are over the age of 13 but under the age of 18, you should use the Service only with the involvement of a parent or guardian and should not submit any PII to Company. If we discover that a person under the age of 13 has provided Company with PII, Company will use commercially reasonable efforts to delete such person’s PII from its system.
3) Use and Disclosure of Collected Information
a) Policy. Company will use PII which you provide and which we obtain from third parties, such as business partners, in a manner consistent with this Policy.
b) Notice. Company may use your PII to send you important information and notices regarding your Service account, the Service itself, to contact you in connection with a promotion or for other purposes disclosed when you provide the information. Company may share PII with third parties (including Company’s hotel and mutli-unit dwelling partners) Company uses to perform certain tasks for the Service such as download/ subscription processing, purchase/order fulfillment, responding to service requests and payment processing. We may also contact you regarding any problems or questions we have relating to your use of the Service, or in our discretion, notify you of changes to the Policy, Terms and Conditions or other policy or terms that affect you and your use of the Service. We may also use information about our Users, including PII, for internal purposes.
c) Registration information; Push Notifications. If you have registered for the Service via a SNS, your SNS friends may see your name, profile picture and descriptions of your activities or other interaction with the Service. Other users of the Service may be able to contact you or send you friend requests through related SNS communications channels. You may need to adjust your SNS settings to limit the information available to your SNS friends regarding your interaction with the Service.
e) Affiliates and Third Parties. Company employees, agents and contractors must have a legitimate business reason to obtain access to your PII. Company may share your PII with outside contractors or agents who help us manage certain tasks (e.g. order fulfillment, statistical analyses). Such contractors or agents will have access to your PII to the extent it is needed to perform their duties and functions and will not share your information with any third party or use it for any other purpose. A company affiliate may collect your PII on Company's behalf when you register on the Site or access Service content using your mobile telephone or tablet device. Such affiliates provide Company with the PII we need to provide you the content and services you requested. Such affiliates may also provide your mobile communications provider with the information it needs to bill you for the content and services you purchased (only if the mobile communications provider is providing billing services). Company may share your PII with its affiliated companies. If you have given us permission to do so, Company may share your PII with advertisers and business partners that are not affiliated with Company but would like to send you information about their products and services. You will always have the option to instruct us not to share your PII with unaffiliated third parties. Additionally, you expressly consent and authorize Company to share your PII with Company’s hotel or other multi-unit dwelling partners (including the owners and/or operators as applicable) where you are staying, reside or are otherwise registered to stay in order to enable the operation of the Company Services and to fulfill any orders, service requests, or the like in connection with your stay or other occupancy. Likewise, as described above, our hotel and multi-dwelling unit partners may share your PII with Company in order for Company to provide the Services. If you are a customer of one of our hotel or multi-unit dwelling partners and no longer wish to be contacted by them, or wish to access, correct, amend or delete any of your PII, please contact such hotel or multi-unit dwelling partner directly.
f) Anonymous Use. Company may share your non-PII and click stream data with vendors that help us customize the advertising and marketing messages you receive as part of the Service. Such vendors will not share your information with any third party or use it for any other purpose. Anonymous click stream and demographic information may also be shared with Company advertisers and business partners. We may disclose non-identifying, aggregated User statistics to third parties for a variety of purposes, including describing our services to prospective partners and other third parties. Examples of such non-personal information include the number of Users who visited the Site during a specific time period or purchased a specific product through the Site.
g) Legal Use. Company may disclose PII in order to protect the legal rights of Company, its affiliates or their employees, agents and contractors; to protect the safety and security of visitors to our Site; to protect the rights, property or safety of Company; or when legally required to do so, at the request of governmental authorities conducting an investigation, or to verify or enforce compliance with the policies governing the Service and applicable laws. If you ask Company to stop using your PII, Company will honor your request but retain any record of your PII as necessary to comply with applicable federal, state or local law.
h) Sale or Transfer. If Company sells all or part of its business, makes a sale or transfer of assets or is otherwise involved in a merger, business transfer or other fundamental corporate change Company reserves the right to disclose, share and/or otherwise transfer User information, including without limitation, PII to a third party as part of such transaction.
i) Promotions. If you choose to participate in a KEYPR promotion, your PII may be disclosed to third parties in connection with such promotion, including without limitation for purposes of posting your entry with attribution or otherwise as permitted in the official rules for the promotion in question, fulfilling your prize or including your name on a winners list. Also, by entering a promotion, we may require you to consent to the use of your PII or other information, such as name, voice or likeness, in advertising, promotional and marketing materials. In addition, we may offer certain promotional content sponsored by or co-branded with a third party, who may obtain the PII that you submit.
4) Third Party Sites and Services
We use various security measures to protect personal information that we collect. We strive to ensure the security of your PII on our systems, including limiting access to the PII contained on our servers. Unfortunately, no security measures are perfect or impenetrable and data transmission over the Internet can be guaranteed to be 100% secure. We cannot and do not ensure or warrant the security of any information you transmit to Company and you do so at your own risk.
6) Access to and Updating Your Information; Sharing and Message Options
a) Information Company Receives from a SNS. In order to manage the information Company receives about you from a SNS, you will need to follow the instructions at that site for updating your information and changing your privacy settings. For example, the privacy management tools for applications on Facebook can be found at https://www.facebook.com/help/325807937506242. You can manage certain aspects of information collection and use by going to the settings of your (mobile) device and reviewing the permissions of each application.
b) Other Methods of Accessing and Controlling your Information.
If you no longer want Company to make active use of your information, you may send us an e-mail to firstname.lastname@example.org. Place "Delete My Account" in the subject line and include your first name, last name, e-mail address and, if applicable the user ID number for the SNS from which you access our apps or services in the body of the e-mail. We will respond to your request within thirty (30) days. Please note that certain records, for example those pertaining to payments or customer service matters, will be retained for legal and accounting purposes. If you have sent or posted content on the Service, We may not be able to delete it.
If you wish to review or change the information Company has about you, please e-mail us at email@example.com.
You may change your e-mail preferences at any time, by navigating to the Settings Screen in the App, and updating your preferences.
You can turn off push notifications by visiting the “options” or “settings” page within the relevant app. You can turn off local notifications by visiting the “options” or “settings” page within the relevant app.
You can stop further use of your geo-location (for example through “check-ins”) by visiting your device's settings for the relevant application or the “settings” page for the relevant app. You can also stop checking in.
7) Collection In and Transfer To and From United States
The Service is operated in the United States. If you are located in the European Union, Canada or elsewhere outside of the United States, please be aware that any information you provide to us may be collected in or transferred to the United States or any other country in which Company or its affiliates, subsidiaries or agents maintain facilities. By using the Service, participating in any of our services and/or providing us with your information, you consent to this transfer.
8) Notice to California Residents / Your California Privacy Rights
California residents are entitled once a year to request and obtain certain information regarding our disclosure, if any, of personal information to third parties for their direct marketing purposes during the immediately prior calendar year (e.g. requests made in 2016 will receive information about 2015 sharing activities). As set forth in this Policy, we comply with this law by offering our visitors the ability to tell us not to share your personally identifiable information with third parties for their direct marketing purposes. To make such a request, please contact us at firstname.lastname@example.org.
9) Contact Us
To communicate with Company about this Policy or Company's collection and use of your PII, to review, correct or delete your PII, or to stop future communication from us, please contact us at email@example.com. You can also contact us by mail at the following address:
Project Cloudkey Inc. d/b/a KEYPR
600 Wilshire Boulevard, Suite 700
Los Angeles, CA 90017
Attention: Legal Department