Last updated: September 2018
- If you have any queries about the policy, please get in touch with us using our contact details and we will do our best to answer your questions.
- This notice applies to personal data provided by our users, our users include our Homeowners, guests who use the Site to search for properties to rent, Guests staying at a Homeowner’s property or other users such as those applying for a job through the Site. In this notice “you” refers to any individual whose personal data we hold or process (other than our staff and contractors).
Information we collect
There are two general categories of information that we collect.
1. Information you give us.
We collect information you share with us when you use the Whistler Platinum Site in order to ensure the adequate performance of contracts between you and Whistler Platinum. The provision of this information is necessary to use the Whistler Platinum Site and, without it, we will not be able to provide you with services that you request.
- Property Inquiry and Booking request. When you submit a property inquiry or request to book accommodation, we require certain information such as your name and email address.
- Property Management request. If you are a Homeowner, when you submit a request for your property to be managed by us, we require certain information about your property and contact and personal information such as your name, email address, and phone number.
- Payment Information. When you book accommodation or a travel-related experience through us, we require certain billing information such as your credit card number and expiry date to process payments and comply with applicable law.
- Communications with Whistler Platinum. When you communicate with Whistler Platinum, we collect information about your communication and any information you choose to provide.
- Other Information. You may otherwise choose to provide us information (such as your itinerary, food allergies, emergency contact information, travel preferences, and information about other guests accompanying you on your stay) when you fill in a form, speak to, or otherwise communicate with a Whistler Platinum representative, conduct a search, respond to surveys, participate in promotions, or use other features of the Whistler Platinum Site.
2. Information we automatically collect from your use of the Whistler Platinum Site.
When you use the Whistler Platinum Site, we collect information about the services you use and how you use them. We process this information for the activities and legal bases described below.
- Usage Information. We collect information about your interactions with the Whistler Platinum Site, such as the pages or other content you view, your searches for homes, bookings you have made, the experiences and activities you book, and other actions on the Whistler Platinum Site.
- Location Information. When you use certain features of the Whistler Platinum Site, we may collect different types of information about your general location (e.g. IP address, postal code).
- Log Data. We automatically collect log information when you use the Whistler Platinum Site. That information includes, among other things: details about how you’ve used the Whistler Platinum Site (including if you clicked on links to third-party applications), IP address, access times, hardware and software information, device information, device event information (e.g., crashes, browser type), unique identifiers, and the page you’ve viewed or engaged with before or after using the Whistler Platinum Site.
- Transaction Information. We collect information related to your transactions on the Whistler Platinum Site or transactions made through the Whistler Platinum Site, including the date and time, amounts charged, and other related transaction details.
Basis on which we process personal data
We hold and process this information given our legitimate interest in protecting the Whistler Platinum Site, to verify and ensure the adequate performance of our obligations under a contract between you and us, and to comply with applicable laws.
How we use the information we collect
The table below sets out how we process your data and the lawful basis for the processing:
|Purpose/Activity||Lawful basis for processing including basis of legitimate interest|
|When you as a Homeowner update or amend your property or availability details||Performance of a contract with you|
|When we assist with a booking for accommodation||Performance of a contract with you. Necessary for our legitimate interests (for running our business and to provide you with products and services requested)|
|When you seek to amend or change a booking or make an enquiry in relation to a booking||Performance of a contract with you. Necessary for our legitimate interests (for running our business and to provide you with products and services requested and to fulfil our statutory obligations). Necessary to comply with a legal obligation|
|To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy notice
(b) Asking you to leave a review or take a survey
(c) When you submit a complaint
(d) Sending relevant information about our products and services to you
|Performance of a contract with you. Necessary to comply with a legal obligation. Necessary for our legitimate interests (to keep our records updated and to study how customers use the services we provide)|
|To administer and protect our business, including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data||Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation). Necessary to comply with a legal obligation|
|To use data analytics to improve the Site, services, marketing, customer relationships and experiences||Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Site updated and relevant, to develop our business and to inform our marketing strategy)|
|To store your contact information for marketing purposes and sending marketing and other promotional communications to you.||Necessary for our legitimate interests in promoting our services.|
Sharing this information
- We may share your information at your direction or as described by us to you at the time of sharing, such as if you, as a guest, have requested us to connect you with a third party vendor or to purchase services from a third party vendor on your behalf, in connection with your booking (e.g., an insurance provider or activities provider). In these situations, you are authorising Whistler Platinum to disclose to these third party vendors information required to book them and to receive the relevant services from them. These third-party vendors are not controlled by Whistler Platinum and personal information shared with them is subject to their privacy policies and practices.
- Credit or debit card payments will be collected by our payment processor.
- In order for payments to be processed, you may need to provide some necessary details to our agent. We tell you about this at the point we collect that information on the Site.
- We may share customer information with third parties to perform services on our behalf in order to improve our services and you hereby consent to us sharing such customer information.
- We may transfer your personal information to a third party as part of a merger, acquisition, sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation, but we will take steps with the aim of ensuring that your privacy rights continue to be protected.
- The Whistler Platinum Site publishes information that is visible to the general public. For example: After completing a booking, guests may write reviews which may appear publicly on Listing pages (and other pages on which we may market accommodations) under their first name, last initial, and general location. If you submit content on our blog, in a public forum, or in a social media post, or use a similar feature on the Whistler Platinum Site, that content is publicly visible. Information you share publicly on the Whistler Platinum Site may be indexed through third-party search engines. If you change your settings or your public-facing content, these search engines may not update their databases. We do not control the practices of third party search engines, and they may use caches containing your outdated information.
- To the extent we collect and remit accommodation taxes and sales taxes, third-party vendors, homeowners, and guests expressly grant us permission, without further notice, to disclose vendors’ and guests’ data and other information relating to them or to their transactions, bookings, accommodations and occupancy taxes to the relevant tax authority, including, but not limited to, the vendor’s or guest’s name, listing addresses, transaction dates and amounts, tax identification number(s), the amount of taxes received (or due) by vendors from guests, and contact information.
- Other than as set out above, we will not disclose any of your personal information without your permission unless we are required by law to do so (for example, if required to do so by a court order or for the purposes of prevention of fraud or other crime).
We will take all reasonable steps to ensure that appropriate technical and organisational measures are carried out in order to safeguard the information we collect from you and protect against unlawful access and accidental loss or damage. These measures may include (as necessary):
- locating our data processing storage facilities in secure locations;
- protecting our servers with software firewalls;
- encrypting all data stored on our server with an industry standard encryption method that encrypts the data between your computer and our server so that in the event of your network being insecure no data is passed in a format that could easily be deciphered;
- when necessary, disposing of or deleting your data so it is done so securely;
- regularly backing up and encrypting all data we hold.
Unfortunately, the transmission of information via the internet and email is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Site; any transmission is at your own risk. Once we have received your information, we will use the strict procedures and security features referred to in this clause to try to prevent unauthorised access.
Your privacy choices
You have the following choices and rights in respect of personal data we hold about you:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Ask us to correct any information that we hold about you which is incorrect, incomplete or inaccurate.
- Ask us to erase your personal information from our files and systems where there is no good reason for us continuing to hold it.
- Object to us using your personal information to further our legitimate interests (or those of a third party) or where we are using your personal information for direct marketing purposes.
- Ask us to restrict or suspend the use of your personal information, for example, if you want us to establish its accuracy or our reasons for using it.
- Ask us to transfer your personal information to another person or organisation.
If you have given your consent to us processing your personal information (for example, consent to receive information about our seminars and events), you have the right to withdraw your consent at any time. To withdraw your consent, please contact firstname.lastname@example.org. Once we have received notification that you have withdrawn your consent, we will no longer process your personal information and, subject to our retention policy, we will dispose of your data securely (although we may in some circumstances need to continue to process your data, if so then we will confirm the reasons for this).
Further Questions? Contact Us
If at any time you would like to contact us with your views about our privacy practices or if you would like to exercise any of your rights, or with any enquiry relating to your personal information, you can do so by emailing us at email@example.com.
Last updated: September 2018
A cookie is a small data file that is transferred to your device (e.g. your phone or your computer). For example, a cookie could allow us to recognize your browser, while another could store your preferences. There are two types of cookies used on the Whistler Platinum Site: (1) “session cookies” and (2) “persistent cookies.” Session cookies normally expire when you close your browser, while persistent cookies remain on your device after you close your browser, and can be used again the next time you access the Whistler Platinum Site.
Why Whistler Platinum uses these technologies
We use these technologies for a number of purposes, such as:
- To enable you to use and access the Whistler Platinum Site.
- To enable, facilitate and streamline the functioning of and your access to the Whistler Platinum Site.
- To better understand how you navigate through and interact with the Whistler Platinum Site and to improve the Whistler Platinum Site.
- To serve you tailored advertising (on the Whistler Platinum Site and on third party websites).
- To show you content (e.g., advertisements) that is more relevant to you.
- To monitor and analyze the performance, operation, and effectiveness of the Whistler Platinum Site and Whistler Platinum advertisements.
- To enforce legal agreements that govern the use of the Whistler Platinum Site.
- For fraud detection and prevention, and investigations.
- For purposes of our own customer support, analytics, research, product development, and regulatory compliance.
We may also allow certain business partners to place these technologies on the Whistler Platinum Site. These partners use these technologies to (1) help us analyze how you use the Whistler Platinum Site, such as by noting the third party services from which you arrived, (2) market and advertise Whistler Platinum services to you on the Whistler Platinum Site and third-party websites, (3) help us detect or prevent fraud or conduct risk assessments, or (4) collect information about your activities on the Whistler Platinum Site, other sites, and/or the ads you have clicked on. For example, to help us better understand how people use the Whistler Platinum Site, we work with a number of analytics partners, including Google Analytics. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-Out Browser by clicking here.
Third parties may also use such tracking technologies to serve ads that they believe are most likely to be of interest to you and measure the effectiveness of their ads both on the Whistler Platinum Site and on other websites and online services. Targeting and advertising cookies we use may include Google, Facebook, Microsoft and other advertising networks and services we use from time to time. For more information about targeting and advertising cookies and how you can opt out, you can visit the Network Advertising Initiative’s opt-out page, the Digital Advertising Alliance’s opt-out page, or http://youronlinechoices.eu. To opt out of Google Analytics for display advertising or customize Google display network ads, you can visit the Google Ads Settings page. To the extent advertising technology is integrated into the Whistler Platinum Site and you opt-out of tailored advertising, you may still receive advertising content. In that case, the advertising content will just not be tailored to your interests. Also, we do not control any of these opt-out links and are not responsible for the availability or accuracy of these mechanisms.
Third party social plugins
The Whistler Platinum Site may use social plugins provided and operated by third parties, such as Facebook’s Like Button. As a result of this, you may send to the third party the information that you are viewing on a certain part of the Whistler Platinum Site. If you are not logged into your account with the third party, then the third party may not know your identity. If you are logged in to your account with the third party, then the third party may be able to link information or actions about your interactions with the Whistler Platinum Site to your account with them. Please refer to the third party’s privacy policies to learn more about its data practices.
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If you choose to decline cookies, some parts of the Whistler Platinum Site may not work as intended or may not work at all.