Effective Date: March 3, 2022
For the purpose of this Policy, “Personal Information” means any information that is reasonably linkable to a specific individual.
1. WHAT PERSONAL INFORMATION DO WE COLLECT ABOUT YOU?
Where applicable, we indicate how we collect your Personal Information. If you do not provide Personal Information when requested, you may not be able to fully use our Site and Services. We may collect Personal Information about you directly from you and from third parties, as well as automatically through your use of our Services.
We collect Personal Information, generally speaking, from the following types of persons:
A “Customer” is a person with whom we have engaged in certain contractual agreements to evaluate real estate investment opportunities and manage them as short-term rental properties.
A "Renter" is a person that is considering or has arranged to visit a property that we manage.
A “Visitor" is a person who uses the Site or with whom we otherwise interact online.
This Policy applies to our use of your Personal Information even if you are acting as a business's employee or contractor and/or are accessing the Site or Services or interacting with Andes STR on behalf of that business.
INFORMATION DIRECTLY COLLECTED FROM YOU
- Registration and check-in. If you are a Renter, we may collect certain Personal Information (whether directly or through third party providers such as AirBnB) to facilitate your booking, including your name, phone number, email address, home postal address, address of submitted property, password, date of birth, and booking information. We may also ask for your email address and password if you register with us. We may also ask for payment and ID information to facilitate your booking.
- Information you Provide. We collect information that you provide directly on the Site, such as when you fill out a web form. We collect also collect Personal Information about prospective Customers from our sales agents and through online forms, such as your real estate purchase history.
- Transaction Information. We collect information about Customers to facilitate transactions, such as taxpayer ID in connection with property management tax filings.
- Communications. If you contact us directly (e.g., via email, SMS, phone call, in-app messaging), we will collect your name, contact details, the content, date and time of your message and any attachments thereto, and other information you may directly provide to us. You may choose to submit your email address and phone number on our Site to receive our updates. You may also provide us with your reviews of our Services or complete surveys regarding our Services.
- Recruitment. If you apply for a job via the “Careers” page on the Site, we will collect your name, contact details, email, phone number and information in your resume. We may also ask you to provide a link to your full LinkedIn profile.
INFORMATION COLLECTED FROM YOUR INTERACTIONS WITH US
- Customer service. If you reach out to us with inquiries or requests, we will keep a record of how your inquiry or request was handled.
INFORMATION AUTOMATICALLY COLLECTED THROUGH USING OUR SITE
- Online usage data. We may automatically collect the following information about your use of our Services through cookies, web beacons, and similar technologies: click data; your domain name; your browser type; operating system type, name, and version; page views; your IP address; location information; the length of time you visit or use our Services; referring URL; access date and time; mobile device ID; language information; device name and model; and other information about your activities within the Services and communications that we send you. Please see the section “Cookies and Other Tracking Mechanisms” below for more information.
- Property usage data. If you are a renter, we collect information about your stay history (e.g., to identify a return guest). We may also automatically collect information regarding the use of an accommodation (e.g., when a door was unlocked). We also register noise levels via a noise detection system installed in accommodations (which only registers decibel levels, not conversations).
INFORMATION WE MAY COLLECT FROM THIRD PARTIES
- Third-Party Online Travel Agency Services. We may receive your booking information via third party partners (e.g., Airbnb), such as your name, email address, phone number, information available in your user account with a third-party travel service and your stay information (e.g., information on the property you are staying in).
- Background Checks. If you are a Customer or a Renter, we may engage with a vendor to verify your criminal history. We may receive your name, date of birth, address and whether or not you passed the check. Our vendor will use county, state and federal criminal databases to run the background checks.
- Vendor and Partner Relationships. We receive Personal Information of employees and other individuals who are contact persons at our partners and vendors, such as contact details and other information relevant to the particular business relationship.
2. HOW WE USE YOUR PERSONAL INFORMATION
In addition to the purposes described above, we use your Personal Information for the following purposes:
- To operate, provide, and maintain our Services, to communicate with you about our Services, to respond to your inquiries, to fulfill our agreements with you, to complete your transactions, and for other customer service purposes.
- To facilitate bookings, we may run a criminal background check who require it for accommodations in the United States, to the extent permitted under applicable law.
- To tailor the content and information that we may send or display to you, and to otherwise personalize your experiences while using our Services. We may also tailor our Services and communications on the basis of your Site browsing history.
- To contact you with newsletters, marketing or promotional materials and other information that may be of interest to you.
- If you are an actual or prospective Renter or Customer, we may market our Services and/or accommodations to you.
- For quality assurance purposes.
- To solicit a review from you about our Services or accommodations.
- To better understand how Visitors access and use our Services in order to improve the quality and value of our Services, provide you with a better experience, and develop new Services, and for other research and analytical purposes.
3. HOW WE SHARE YOUR PERSONAL INFORMATION
We may employ third party companies and individuals to support our Services. We do not sell or otherwise disclose your Personal Information for purpose unrelated to our Services, unless otherwise described in this Policy. We may share your Personal Information under the following circumstances:
- Service providers: we may disclose Personal Information we collect about you to third party vendors, service providers, contractors or agents who perform functions on our behalf, including to facilitate our Services, to provide the Services on our behalf, to perform Site-related services (e.g., maintenance services, database management, web analytics, fraud detection and improvement of the Site's features), to perform background checks, to send marketing communications, to manage job applications that we receive via the career page on our Site, to aggregate reviews, or to assist us in analyzing how our Site and Services are used. We require these service providers to safeguard the privacy of Personal Information they process on our behalf.
- Third party online travel agency services: when you book an accommodation via a third party travel agency service, we may share your Personal Information with such service in order to manage your booking.
- Property Management: we may share reports with Customers and property managers regarding the use of their properties, such as cleaning reports. Additionally, we may share guest names and dates of stay at their properties for security purposes (e.g., to keep out individuals who are not guests). We may share Renters' name, email address, phone number, ID, birthday and address for such purposes. If permitted by applicable law, we may also share pass/fail results of background checks that we carry out.
- Advertising and analytics partners: we may share Personal Information about you with third party advertising partners to serve advertisements regarding goods and services that may be of interest to you. We may also share information about the use of our Site and Services with third parties for analytics purposes. Some of our advertising partners are members of the Network Advertising Initiative (“NAI”) or the Digital Advertising Alliance (“DAA”). If you do not wish to receive personalized ads, please use the NAI's Opt-Out Tool or the DAA's Opt Out Tool to opt out of receiving web-based personalized ads from member companies. You can access any settings offered by your mobile operating system to limit ad tracking, or you can install the AppChoices mobile app to learn more about how you may opt out of personalized ads in our Apps.
- Business transfers: We may sell, transfer or otherwise share some or all of its assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy, or other similar transaction.
- Compliance with laws and law enforcement; guarantee program: Andes STR cooperates with government and law enforcement officials (e.g., immigration offices, customs authorities, anti-terrorism authorities) and private parties to enforce and comply with the law. We will disclose your Personal Information to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Andes STR or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, unethical or legally actionable activity. We will disclose any information about you to government or law enforcement officials and to our insurance services providers as we, in our sole discretion, believe necessary or appropriate to protect the property and rights of Andes STR or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, unethical or legally actionable activity.
- Testimonials: We may post your testimonial on the Site along with your name.
4. COOKIES AND OTHER TRACKING MECHANISMS
- Cookies: We use “cookies” to collect information. A cookie is a small data file that we transfer to your computer's hard disk for record-keeping purposes. We may use persistent cookies to save your login information for future logins to the Services. Second, we use session tracking cookies to enable certain features of the Services, to better understand how you interact with the Services and to monitor aggregate usage by Visitors and web traffic routing on the Services. We use the following cookies:
- Google: We use Google Analytics cookies to analyze our 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 also use Google cookies to serve ads based on a Visitor's prior visits to our Site. You can learn more about these cookies here and disable these cookies via Google's Ads Settings or Ad Settings for mobile apps.
You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions of the Site or all functionality of the Service. For further information, visit allaboutcookies.org.
- Web beacons: our Site may contain electronic images known as Web beacons (sometimes called single-pixel gifs) and are used along with cookies to compile aggregated statistics to analyze how our Site is used and may be used in some of our emails to let us know which emails and links have been opened by recipients. This allows us to gauge the effectiveness of our customer communications and marketing campaigns. For example, we use the Facebook pixel for remarketing and to track the effectiveness of advertisements. You can learn more about how to control Facebook's collection of your information by visiting https://www.facebook.com/policies/cookies.
- Log data: when you visit the Site, whether as a Customer or a Visitor, our servers automatically record information that your browser sends whenever you visit a website (“Log Data”). This Log Data may include information such as your computer's Internet Protocol (“IP”) address, browser type or the webpage you were visiting before you came to our Site, pages of our Site that you visit, the time spent on those pages, information you search for on our Site, access times and dates, and other statistics. We use this information to monitor and analyze use of the Site and the Service and for the Site's technical administration, to increase our Site functionality and user-friendliness, and to better tailor our Site to our visitors' needs.
5. CHILDREN'S PRIVACY
The Site is not directed to individuals under 13. We do not knowingly collect Personal Information from children under 13. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us. If we become aware that a child under 13 has provided us with Personal Information, we will delete such information from our files.
6. LINKS TO OTHER WEBSITES
Our Site contains links to other websites, to which this Policy applies. If you choose to visit an advertiser by clicking on a banner ad or other type of advertisement, or click on another third party link, you will be directed to that third party's website. The fact that we link to a website or present a banner ad or other type of advertisement is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites.
7. DATA SECURITY
We take commercially reasonable measures for safeguarding your Personal Information. We follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure. If you have any questions about security on our Site and Services, you can contact us.
8. DATA RETENTION
When deciding how long we retain Personal Information, we take into account various criteria, such as the type of Services requested by or provided to you, the nature and length of our relationship with you, possible re-enrolment with our Services, the impact on the Services we provide to you if we delete some information from or about you, mandatory retention periods provided by law and the statute of limitations.
9. YOUR RIGHTS AND CHOICES
- Marketing opt out: if you decide at any time that you no longer wish to receive marketing communications from us, please follow the unsubscribe instructions provided in any of the communications.
- Changing or deleting information: all Customers may review, update, or correct the Personal Information in their registration profile by contacting us at [email protected] or, if applicable, editing the relevant part of their profile. If you would like us to cancel your account, please contact us and we will attempt to accommodate your request if we do not have any legal obligation or a legitimate business reason to retain the information contained in your account. Please see below for privacy contact information.
- most Internet browsers automatically accept cookies, but you may be able to change the settings of your browser to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you set your browser to reject cookies, parts of our website may not work for you.
10. CROSS-BORDER DATA TRANSFERS
The Personal Information we collect is processed in the United States or in other jurisdictions worldwide. The United States and the other jurisdictions to which we transfer information may not have equivalent data protection laws as your home jurisdiction. Your use of the Site and/or Services is your consent to that transfer.
11. CHANGES TO THIS POLICY
We may modify this Policy at any time for any reason. Any modification or amendments to this Policy are effective as of the date posted above. If any modifications or amendments materially change how we use information, we will provide notice on the Site or we will notify you by email.
12. HOW TO CONTACT US
For all other inquiries, please contact us at [email protected]