This Privacy Policy describes the principles and practices that apply to Personal Information (defined below) collected from users of our services (“you”) on our Site (defined below), in telephone or e-mail communications, or in interviews, surveys, contests, promotions, raffles or sweepstakes.
Simply put:
We will not collect Personal Information without your knowledge and permission;
We will not knowingly disclose your Personal Information to third parties, except as provided in this Privacy Policy;
We will allow you to view, correct or modify your Personal Information; and
We will take reasonable steps to protect the security of the Personal Information we collect from you.
Your California Privacy Rights
Under California Law, California residents have the right to request in writing from businesses with whom they have an established business relationship, (a) a list of the categories of personal information, such as name, e-mail and mailing address and the type of services provided to the customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes and (b) the names and addresses of all such third parties. To request the above information, please e-mail us at: info@realrewardscard.com with a reference to California Disclosure Information.
We will respond to such requests to information access within 30 days following receipt at the e-mail or mailing address stated above. If we receive your request at a different e-mail or mailing address, we will respond within a reasonable period of time, but not to exceed 150 days from the date received. Please note that we are only required to respond to each customer once per calendar year.
The remainder of this policy describes our Personal Information handling practices in detail.
1. Definitions
In this Privacy Policy, terms that commence with a capital letter are defined in this Section.
“Guest” means an individual who searches and Books Products or Services on our Site without being a Member.
“Member” means an individual who has registered on the www.villanaturacommunity.com site.
“Member ID” means the e-mail address Members use (with their password) to log into our Site.
“Villa Natura ,” “us,” “our” or “we” means Villa Natura and its subsidiaries and affiliates.
“Personal Information” means any information, recorded in any form, about an identified individual, or an individual whose identity may be inferred from the information. This includes, for example, name, e-mail and mailing address, telephone number, billing and account information and other information incidental to providing Products or Services (including information about individuals traveling with an individual who Books on our Site).
“Products or Services” means the airline travel, hotel accommodation, car rental, ground transportation, tours, theater tickets, attractions, travel insurance and other items available from our Site.
To “Book” means to reserve.
“Session Data” means usage information, such as the type of Internet browser and operating system an individual uses, the domain name of the site from which the individual came, the date, time and duration of the individual’s visit, the number of visits to our Site, the pages viewed and the number of cookies accumulated, and, in the case of the Villa Natura mobile site and applications, also means the unique identifier of an individual’s mobile device, the type of mobile device the individual uses and the application version.
“Site” means the www.villanaturacommunity.com site, the villanaturacommunity.com mobile site or the Villa Natura mobile applications and their respective sub sites together with the respective content, Products and Services available from these sites/applications or sub sites.
2. Consent
BY SUBMITTING PERSONAL INFORMATION TO US, AND/OR BY USING OUR SITE, YOU AGREE THAT WE MAY COLLECT, USE AND DISCLOSE SUCH PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY AND AS PERMITTED OR REQUIRED BY LAW.
If you do not agree with these terms, do not provide any Personal Information to us. If you refuse or withdraw your consent, or if you choose not to provide us with any required Personal Information, we may not be able to provide you Products or Services.
Minors
Minors (as defined under the laws of their jurisdiction or residence) are not eligible to register for, use or Book the Products or Services. We do not knowingly collect Personal Information from any Minor, and will not use this information if we discover that it has been provided by a Minor.
Other Travelers or Contacts
If you Book Products or Services for other travelers using your Member ID and password, or if you provide us with contact information of a third party for Villa Natura Care Alerts, you must make sure that you have the right to do so. By providing the Personal Information of another traveler or third party, you represent that you have all necessary authority and/or have obtained all necessary consents from such person to enable us to collect, use and disclose his or her Personal Information as set forth in this Privacy Policy.
3. Personal Information we collect
We collect only such information as necessary to provide Products and Services to you.
When you are just visiting you can visit certain areas of our Site without revealing who you are or logging into our Site.
When you visit our Site as a Guest or Member, we collect Session Data through cookies and pixel tags.
When using the Villa Natura mobile site or applications, you may search for Products and Services in the area in which you are located. If you choose to do so, depending on the mobile device or application you are using, we may collect your geo-location information to search for the applicable Products and Services or to personalize and improve your individual viewing experiences on our Site and provide information that may be of interest to you. You may at any time disable our collection and use of your location information by turning location services off at the device level.
When you register as a Member
When you register with us as a Member, we collect Personal Information that is necessary to provide Products and Services. You must provide your name and e-mail address. You also must choose a password, which will be required to gain access to portions of our Site reserved for Member use. We might also request your home zip code.
You may elect to provide other information. Such information may include, for example, gender, activities and lifestyle preferences or preferred destinations.
When you Book Products or Services as a Member
When you Book Products or Services as a Member, you must provide payment and billing information and other information required by the travel service provider(s). Such information may include, for example, date of birth, gender, driver information or similar information.
If you choose to use our E-mail Your Itinerary feature, we will send the individual(s) you identify a one-time e-mail with the applicable information. We do not permanently store the name or e-mail address of such individuals.
When you Book Products or Services for a third party
When you Book Products or Services for a third party using your Member ID and password, you must provide that third party’s name and contact information, payment and billing information and other information required by the travel service provider(s).
When you Book Products or Services as a Guest
When you Book Products or Services as a Guest, you must provide Personal Information required by the travel service provider(s). You must also provide an e-mail address so that we can send you our welcome e-mail and a confirmation of the booking. With the confirmation, we will provide you with a temporary password so that you can return to our Site if you wish to review information about the booking.
When you participate in contests, promotions, raffles or sweepstakes
We may offer you the chance to win a variety of travel-related prizes by sponsoring contests, promotions, raffles or sweepstakes. If you choose to participate, we will collect Personal Information such as your name or e-mail or mailing address.
If a third party administers the contest, your participation may be subject to additional terms and conditions and that third party’s privacy policy. We are not responsible for such third parties. You should carefully review these third parties’ terms and conditions.
When you participate in a survey or a focus group
From time to time, we may invite you to participate in a survey or a focus group. You are free to participate or not. We will collect the responses you provide, and will make them anonymous by aggregating them with those of other participants. If you use a bulletin board, blog or chat room on our Site, you should be aware that any Personal Information you submit there can be read, collected or used by other users of these forums, and could be used to send you unsolicited messages. We are not responsible for the Personal Information you choose to submit in these forums. If you wish to request the removal of your Personal Information from our blog, you can do so by contacting us as indicated in Contact Information. In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why.
When we advertise on third party sites
When you visit a site on which we advertise and click through our advertisement, we may place cookies on your computer or use pixel tags. The information that we collect through this technology is not personally identifiable.
When you call or write to our Customer Service
When you call or write to our Customer Service, we collect contact information, including, for example, name, phone number, e-mail or mailing address, and information about the relevant booking as necessary to assist you. For example, if you call for assistance with a pre-existing booking or to Book Products or Services, we may request your name, contact information and payment and billing information.
When we send e-mails or e-newsletters
When we send e-mails or e-newsletters, we may insert a pixel tag in the e-mail. If you choose to use our Forward to a Friend feature, we will send your friend(s) a one-time e-mail about the applicable information. We do not permanently store the name or e-mail address of such individuals.
Supplementation of Personal Information
In order to provide certain services to you, we may on occasion supplement the Personal Information you submitted to us with information from third party sources:
Address Verification: If you Book Products or Services, we use third parties in order to verify your address information during the credit card authorization process.
Enhancement of Profile Information: We obtain marketing data from third parties and add it to our existing user database, to better target our advertising and to provide pertinent offers for which we think you would be interested. To enrich our profiles of individual customers, we tie this information to the Personal Information you submitted to us.
4. How we use the information we collect
We use Personal Information in order to provide and enhance the Products or Services offered:
- To record your travel preferences, make reservations or acquire travel insurance on your behalf or communicate with you about your travel plans;
- To issue invoices, administer accounts, collect and process payments;
- To provide tips or guidance on how to use our Site, inform you of new features on our Site or provide other information that may be of interest to users;
- To personalize the service we provide to you, tailor your experience at our Site to your interests and make more appropriate travel recommendations;
- To send you e-mails, e-newsletters, personalized offers via direct messaging or other communications about our services, if you have subscribed to receive this information or you have not advised us that you do not wish to receive such communications;
- To manage our Site, diagnose technical problems, improve content and allocate the resources of our systems so that your experience with our Site is as efficient as possible;
- To process and track your transactions and to send you information about our and our affiliates’ and business partners’ products and services and other information and materials that may be of interest to you;
- To develop, enhance, market, sell or provide Villa Natura ’ Products or Services, or those of companies with which we have a commercial relationship, but only if you have granted us permission to do so or we are otherwise able to do so under applicable law;
- To evaluate credit standing and to match credit bureau or credit reporting agency information;
- To investigate, detect and protect Villa Natura and other third parties against error, negligence, breach of contract, fraud, theft and other illegal activities;
- To effect a corporate transaction in connection with the sale, merger, spin-off or other corporate reorganization of our corporation, where the information is provided to the new controlling entity in regular course of business;
- To audit compliance with our policies and contractual obligations; As permitted by, and to comply with, any legal or regulatory requirements or provisions; or For any other purpose to which you consent. Contests, Promotions, Raffles and Sweepstakes
We may send you additional communications only if you have specifically requested to receive our e-mails, e-newsletters, personalized offers or other promotional materials when filling out the contest or promotion form.
We will share the information you provide us with the entities with which we may have teamed to propose a joint promotion.
Session Data
We use Session Data, collected through cookies and pixel tags, to better understand how our Site is navigated, how many visitors arrive at specific pages, the length and frequency of stays at our Site, the variety of searches of our Site’s database, the types of browsers and computer operating systems used by our visitors and the Internet Protocol addresses from which visitors connect to our Site.
We also use this information to improve our Site’s content and ease of use, to personalize and improve your individual viewing experiences on our Site and provide information that may be of interest to you.
Pixel Tags
We use pixel tags to monitor the open rate of our communications. This helps us understand the effectiveness of communications we send. We do not use this information for any other purpose.
Survey and Focus Groups
When you participate in surveys or focus groups, your participation and responses will be kept confidential and will not be shared with third parties without your permission, except with our service providers.
Aggregated Information
Aggregated information is information recorded in any form about more than one individual, where the identity of the individual is not known and cannot be inferred from the information. We may use aggregated information to describe our user base to current or potential partners, investors and advertisers; after a survey, to understand and respond to market needs and preferences; or to make recommendations to other users of our Site. For example, if users of our Site who have traveled to a particular destination told us that they had positive experiences at a hotel in that destination, we might recommend that hotel.
What we do NOT do
We do not and will not, at any time, request your credit card information, Member ID, password or national identification numbers in a non-secure or unsolicited e-mail or telephone communication.
Identity theft and the practice currently known as “phishing” are of great concern to us. Safeguarding information to help protect you from identity theft is our priority. For more information about phishing, you may want to visit the Federal Trade Commission at http://www.ftc.gov/bcp/edu/pubs/consumer/alerts/alt127.shtm
5. To whom we disclose Personal Information
From time to time, we may disclose your Personal Information as follows:
To those travel service providers with which you make arrangements through our Site, for example airlines, car rental, hotel, ground transportation, theater, attraction or travel insurance. We provide them with the Personal Information needed to make and complete the booking or reservation;
To organizations that perform services for or on behalf of Villa Natura , for example to provide customer service, deliver tickets, ship items, process credit cards, for research, marketing, data processing, to measure the use of our Site, to facilitate usage by a visitor or to offer credit card services or evaluate your creditworthiness. We will share with these companies only that Personal Information which they need to work on our behalf. Some of these service providers may be located in countries outside the US and outside the European Economic Area (“EEA”).Your Personal Information will be provided to these organizations only if they agree to use such information solely for the purpose of providing services to Villa Natura , and under the instructions of Villa Natura , and with respect to that information, to act in a manner consistent with the relevant principles articulated in this Policy. By submitting your personal data, you agree to the transfer, storing and processing of your data outside the US and outside the EEA;
We may collaborate with other companies to offer you additional Products or Services, for example, through sweepstakes, raffles and promotions. We will share Personal Information that is necessary for these other companies to provide the Products or Services that you have requested. This policy does not cover the use of your Personal Information by these other companies. We encourage you to read a company’s privacy polic
y before requesting any of its products or services; To protect our Site and our rights under our Terms and Conditions; to protect ourselves against liability or prevent fraudulent activity; or where it is necessary to permit us to pursue available remedies or limit any damages that we may sustain;
To effect a corporate transaction, in connection with the sale, merger, spin-off or other corporate reorganization of our corporation, where the information is provided to the new controlling entity in regular course of business;
Where the information is public; or To our insurers and to regulatory agencies.
Disclosure without Consent
Please note that there are circumstances where the use or disclosure of Personal Information may be justified or permitted, or where Villa Natura may be obligated to disclose information without consent. Such circumstances may include:
If required to comply with a subpoena or warrant issued or an order made by a court, person or body with jurisdiction to compel the production of information or to comply with the rules of a court relating to the production of records;
If we receive a formal request to disclose your Personal Information in connection with a legal action, we will attempt to contact you about it, if permitted by law, via the e-mail address you provided during registration, before we respond to that request.
If we believe in good faith that a law, regulation, rule or guideline requires it;
To a person who needs the information because of an emergency that threatens the life, health or security of an identifiable person or group; or Where it is necessary to collect monies owing to us.
National Security
In order to protect national security and to ensure travel security, the United States Government and other governments may request access to passenger name records, which typically includes name, flight origin, flight destination, flight time, duration of flight, seat location, travel agent, form of payment, credit card numbers, travel itinerary, address, telephone number and meal requests. In response to such request, Villa Natura and/or its providers will give access to all the information you provide at the time of making the booking to the applicable government agencies of the countries to or from which you are traveling.
6. How we retain and store Personal information
My Trips and My Account
If you are a Member, we store your Personal Information in My Trips and My Account. You can access My Trips and My Account from the home page of our Site, after logging onto our Site. My Trips contains information about your current, canceled or past trips. My Account contains your name, e-mail address, e-mail and password settings, and departure city from which you usually travel. It may also contain other information so that you do not need to re-enter it each time you Book a Product or Service. For example, My Account may contain your billing information unless you tell us not to store it. It may also contain your preferences for seat selection or special meals, details about your participation in loyalty or awards programs and applicable membership numbers and other travel preferences. We also keep in My Account all other information that you have elected to provide us, such as gender, activities and lifestyle preferences and favorite destinations.
You can access, modify or close your account as described in How to access, modify, or close your account.
Third Parties’ Personal Information
We will retain in your My Account, the Personal Information of individuals for whom you have made reservations or to whom we have sent Villa Natura Care Alerts on your behalf. You can access or modify these third parties’ Personal Information at any time, as described in How to access, modify, or close your account.
Retention and Storage
We will retain your Personal Information in our databases in accordance with our Records Management Policy and applicable laws. This period may extend beyond the end of your relationship with us, but it will be only as long as it is necessary for us to have sufficient information to respond to any issues that may arise later. For example, we may need or be required to retain information to allow you to obtain credit for a trip you Booked but had to cancel. We may also need to retain certain information to prevent fraudulent activity; protect ourselves against liability, permit us to pursue available remedies or limit any damages that we may sustain; or if we believe in good faith that a law, regulation, rule or guideline requires it. Your Personal Information will be stored in secured locations and on servers controlled by Villa Natura, located either at our offices or at the offices of our service providers as described in How we protect Personal Information.
7. How we protect Personal Information
Villa Natura employs physical, administrative and technical safeguards to help protect the confidentiality and integrity of Personal Information and to reduce the risk of loss, misuse, unauthorized access, disclosure or modification of Personal Information. When Personal Information is sent to our service providers, we require in our contracts with them that they protect all Personal Information in a manner consistent with the principles articulated in this Privacy Policy.
If you choose to contact Villa Natura through our Site, you should be aware that any information transmitted electronically via the World Wide Web might not be secure. Villa Natura assumes no liability for the loss of any information that you transmit to us via the World Wide Web. However, if you provide your credit card information on our Site’s credit card forms or if you choose to search for Products and Services, through the Villa Natura mobile applications, that are located near you and we collect your geo-location, we encrypt the transmission of that information using secure socket layer technology (SSL).
In communicating with you, we may send e-mail as unencrypted plain text because we are aware that most Members and Guests cannot readily process encrypted e-mail. This is done for your convenience, but with the security concern that, if misrouted or intercepted, it could be read more easily than encrypted e-mail.
8. How to access, modify or close your Account
We endeavor to ensure that Personal Information is as accurate, complete and current as necessary for the purposes for which we use that information. We encourage you to visit My Account to review your Personal Information.
You can access your Personal Information in My Account and update it or delete inaccuracies, as necessary. For example, you can change at any time your e-mail address, activities and lifestyle preferences, favorite destinations or your preferences for receiving or not receiving our e-mails, e-newsletters or instant messaging customized advertisements. If you wish to modify your Personal Information or close your account, you can do so by contacting us as indicated in Contact Information. We will respond to such requests to information access within 30 days following receipt at the e-mail or mailing address stated above. If we receive your request at a different e-mail or mailing address, we will respond within a reasonable period of time, but not to exceed 150 days from the date received.
If you request that we close your account, we will promptly do so, to the extent possible. Once your account is closed, however, you will not be able to use many of the services available on our Site to Members, unless you re-register.
Please remember that we may not be able to honor your request if we are legally obligated to retain information, or for other reasons described in Retention and Storage.
9. Privacy
Cookies and pixel tags
A cookie is a small text file that our computer sends to your computer, and that your computer sends back to us each time you make a request from our Site. A cookie contains a unique identification number that identifies the visitor’s browser, but not necessarily the visitor. A pixel tag is a small graphic image similar to a cookie. When you access our Site, our computer may seek to place cookies or pixel tags on your computer to collect Session Data. Cookies and pixel tags are used to help us recognize you when you visit our Site again or to help us customize your online experience. Unless a visitor specifically informs us of his/her identity (e.g. by registering with us), we will not know who the individual visitor is.
Most Internet browsers automatically accept cookies. You can instruct your browser, by editing its options, to stop accepting cookies or prompt you before accepting a cookie from the sites you visit. You can learn more about the use of cookies by visiting http://networkadvertising.org or http://www.allaboutcookies.org. If you decide not to accept our cookies, you will be able to access those parts of our Site that are available to the general public, but you will not be able to access many of Products and Services.
Third Party Advertisers
We work with third parties to serve ads on our Site and to serve ads on sites owned or operated by other companies. Our ad servers, and those of our partners, use cookies and pixel tags in order to anonymously identify your browser. Some third-party ad companies, such as ad networks, may combine anonymous information obtained in connection with activity on our Site with information obtained from other sources and/or sites. We do not use or share any Personal Information with any of our ad server partners, media partners or ad networks without your authorization.
We use anonymous Session Data, such as the destination of your search, in order to advertise to you on our Site and on other sites. We do not sell your Session Data to any other party in connection with our ad programs but we may use it in order to run ads on behalf of others, such as travel suppliers. For example, we may serve an airline’s ad to you while you are on another site, on behalf of that airline. In such cases, we use a third-party called AppNexus to anonymously identify your browser while on another site. If you wish to opt-out of this kind of advertising, you can either delete cookies on your browser from adnx.com or you can click on the following link http://www.networkadvertising.org/managing/opt_out.asp. None of our ad programs include any of your Personal Information. By opting out of AppNexus you may still receive ads from Villa Natura or ads from other parties that are broadly targeted (not on the basis of your Session Data).
Opting-Out
As part of the registration process we give you the ability to receive via e-mail or direct messaging information about Products and Services, updates to our Site and customized advertisements and promotions that are targeted to your specific interest, such as flight specials, promotions, contests, sweepstakes and other travel opportunities available on our Site and/or sponsored by our travel service providers and advertisers. We send this information directly ourselves or via third party service providers.
If you do not opt-out from receiving these communications about our Site, we will send them to you.
At any time you may change which of the communications you wish to receive or not, by changing your preferences as described in How to access, modify or close your account. In addition, in our e-mails and other communications we will include instructions on how to unsubscribe and inform us of preferences if you decide you do not want to receive any future marketing or promotional e-mails from us.
Monitoring
Villa Natura may from time to time monitor and review any information transmitted or received through our Site, or through telephone or e-mail communications, for quality assurance and other purposes. We reserve the right to censor, edit, remove or prohibit the transmission or receipt of any information that Villa Natura deems inappropriate or in violation of our Terms and Conditions. During monitoring the information may be examined, recorded or copied.
Links
When you click on a third party’s link from our Site, or from an ad served by AppNexus, you will entering that third party’s site, over which we have no control. We are not responsible for third party sites. You should carefully review the privacy statements of any other sites you visit, because those privacy statements will apply to your visit to such other sites and may be very different from this Privacy Policy.
10. Changes to the Privacy Policy
Changes to the Privacy Policy and Changes in Ownership
We may change or supplement this Privacy Policy from time to time. We may also undergo a change of ownership. Privacy Policy changes will apply to the information collected from the date we post the revised Privacy Policy to our Site, as well as to existing information held by us.
If we decide to change this policy in a material way, we will obtain the necessary consents required under applicable privacy laws if we seek to collect, use or disclose Personal Information for purposes other than those to which consent has been obtained, unless otherwise required or permitted by law. If we make any material changes we will notify you by e-mail (at the e-mail address specified in your account) or by means of a notice on our Site prior to the change becoming effective. If any proposed change is unacceptable to you, you may request that we close your account.