Effective Date: June 8, 2015
Table of Contents
1. Use of Information: We primarily use the information we collect through the Services in connection with your use of the Services and to communicate with you regarding news, special offers and other information.
2. Sharing of Information: We may share the information we collect through the Services with our vendors and third party business and marketing partners, including companies who sponsor and offer sweepstakes, contests and similar promotions through the Services. We may also share information about you for legal and business reasons.
3. Third Parties Collecting Information Through the Services: The Services may contain content served by third parties, including videos and advertisements, and we work with third party service providers to serve advertisements on the Services and elsewhere online. In connection with providing content and services, third parties may collect certain information about you and your visits to this or other web sites and we may receive information regarding the use of the Services and the effectiveness of our advertisements. These advertising networks, advertisers, ad agencies, analytics service providers and other vendors may set and access their own tracking devices (including cookies and web beacons) and they may otherwise collect or have access to information about you and your online browsing activities.
1. Registration and Other Information You Provide
The Services are general audience services and are not intended for individuals younger than the age of 13. We do not knowingly collect Personal Information from individuals younger than the age of 13 through our online services. If we discover that we have inadvertently collected personal information online from anyone younger than the age of 13, we will use commercially reasonable efforts to delete that information.
2. Information Third Parties Provide About You
3. Social Media/Integration With Third Party Platforms
The Services may permit you to interact with a third party site or service, such as enabling you to “like” us on another site or “share” content from the Services with other sites (a “Social Networking Service”). If you choose to “like” or “share” content or to otherwise post information from or via the Services to a Social Networking Service, that information may be publicly displayed, and the third party may have access to certain information about you and your use of the Services. Similarly, if you interact with us through a Social Networking Service, we may have access to information about you (for example, if you “like” or “follow” our page on a third party site). Please note that if you mention or comment about us or the Services in your post to a third party platform, the third party platform may allow us to publish your post on the Services.
4. User Content
The Services may provide you the opportunity to post content publicly through interactive features. You may choose, through such features or otherwise, to submit or post reviews, comments, photographs, audio files, video files, and suggestions related to the Services or otherwise post free form comments (collectively, “User Content”). Please note that certain information, such as your name and state of residence, and a link to any website URL you provide may be publicly displayed by the Services along with your User Content. However, we will not publish your e-mail address or other contact information with these comments.
5. Information We Collect Automatically
We and our third party service providers (including analytics providers, advertising companies and third party content providers), may automatically collect certain “Usage Information” whenever you visit or interact with the Services. “Usage Information” typically includes the browser and operating system you may be using, the URL or advertisement that referred you to the Services (if applicable), the search terms you entered into a search engine that lead you to the Services (if applicable), all of the areas within the Services that you visit, and the time of day you used the Services, among other information relating to your use of the Services. We may use Usage Information for a variety of purposes, including analyzing and improving the Services and products, to provide special offers, and to select appropriate content to display to you.
In addition, we automatically collect your internet protocol (IP) address, mobile device identifier or other unique identifier (“Device Identifier”) for any computer, mobile phone or tablet, or other device you may use to access the Services. A Device Identifier is a number that is automatically assigned or connected to the device you use to access a Service, and our servers identify your device by its Device Identifier. Some mobile service providers may also provide us or our third party service providers with information regarding the geographic location of the device used to access a Service. Usage Information is generally non-identifying, but if we associate it with you as a specific and identifiable person, we treat it as Personal Information.
Note that your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, we currently do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” please visit www.allaboutdnt.com.
6. Cookies and Similar Technologies
The Services may include the following tracking technologies, and similar technologies, and which may be set and controlled by us or by our third party providers:
Cookies: A cookie is a data file placed on your computer or other device when you visit the Services or otherwise access our online content. Cookies may be used for many purposes, including, without limitation, remembering you and your preferences, tracking your visits to our web pages, and facilitating your check-out and purchases. We employ Adobe Flash cookies in certain situations where we use Flash to provide content such as video clips or animation. We do not use Flash cookies to serve interest-based advertising. For more information about Flash and the privacy choices Adobe offers, visit www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html. If you choose to disable cookies or to adjust your Flash privacy settings, some features of the Services may not function properly.
Web Beacons: Web beacons are small graphic images or other web programming code that may be found within the Services and our communications with you. Web beacons are used to recognize certain types of information on your computer such as cookies, the time and date a page is viewed, and a description of the page where the web beacon is placed. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Services, to monitor how users navigate the Services, and to count whether an e-mail we sent was opened. Web beacons may be used to collect certain Personal Information (for example, the email address associated with an email message).
Embedded Scripts: An Embedded Script is programming code that is designed to collect information about your interactions with the Services, such as the links you click on. The code is temporarily downloaded onto your computer or other device for use when you connect to the Services.
HOW WE USE INFORMATION ABOUT YOU
We may use information about you, including Personal Information and Usage Information, to:
1. process a transaction, including your registration with the Services and verifying information you provide is active and valid;
2. allow you to participate in features we offer or to provide related customer services (for example, to respond to your questions, complaints or comments);
3. tailor content, recommendations and offers we display to you on the Services and elsewhere online;
4. send you information regarding us or information from us relating to a third party, including our parent or affiliated companies;
5. improve the Services and our products, including asking you to participate in surveys, and for other internal business purposes;
6. contact you with regard to your use of the Services including, in our discretion, changes to our policies; and
Third Party Marketing Partners: We may share the Personal Information we collect through the Services with our subsidiaries and affiliates, and with third party business and marketing partners, including companies who sponsor and offer sweepstakes, contests and similar promotions through the Services. Those third parties may reach out to you for their own marketing purposes. California Residents: for information on how to request additional information about third parties with whom we share Personal Information for their marketing purposes, please click here.
Sweepstakes, Contests and Promotions. We may work with third parties that sponsor or offer sweepstakes, contests, and other promotions. By participating in a promotion, you are agreeing to the terms, conditions or official rules that govern that promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing us and the sponsor(s) of the promotion to use your name, voice, likeness or other indicia of persona in advertising or marketing. If you choose to enter a promotion, Personal Information may be disclosed to third parties or the public in connection with the administration of such promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law or permitted by the promotion’s official rules, such as on a winners list.
Third Parties Providing Services on Our Behalf. We may provide third parties with access to user information, including Personal Information, in order for them to perform certain services on behalf of us or you, such as fulfilling and processing contest entries, tracking analytics, sending communications on our behalf or performing other administrative services.
Administrative and Legal Reasons. We may also transfer and disclose user information, including Personal Information, to third parties: (i) in the event we are required to respond to subpoenas or other legal process or if in our opinion such disclosure is required by law; (ii) at the request of governmental authorities conducting an investigation; or (iii) to protect and/or defend the Terms and Conditions or other policies applicable to the Services or to protect the personal safety, rights, property or security of the Services or any individual. We may also use Device Identifiers, including IP addresses, to identify users, and may do so in cooperation with copyright owners, Internet service providers, wireless service providers or law enforcement agencies in our discretion.
Business Transfers. We may share Personal Information with our parent, and with our subsidiaries and affiliated entities primarily for business and operational purposes. We reserve the right to disclose and transfer all information related to the Site, including Personal Information: (i) to a subsequent owner, co-owner or operator of the Sites or one of our databases; or (ii) in connection with a corporate merger, consolidation, restructuring, the sale of certain of our ownership interests, assets, or both, or other company change, including, without limitation, during the course of any due diligence process.
THIRD PARTY AD NETWORKS, ANALYTICS PROVIDERS AND SIMILAR THIRD PARTIES
The Services may contain content served by third parties, including videos and advertisements, and we may work with vendors (including network advertisers, ad agencies, and analytics companies) to provide us with information regarding traffic on the Services, to serve our advertisements through the Services and elsewhere online, and to provide us with information regarding the use of the Services and the effectiveness of our advertisements. In connection with serving content and providing analytics and advertisement services, third parties may collect certain information about you and your visits to the Services or other web sites. These third parties may set and access their own tracking technologies (including cookies and web beacons) and may otherwise collect or have access to your Device Identifier and information about your visits to and activity on the Services, as well as other web sites or online services. Some of these third parties may collect Personal Information over time when you visit the Service or other websites and services.
Cookies and web beacons, including those set by third party network advertisers, may be used to, among other things, target advertisements, prevent you from seeing the same advertisements too many times and to conduct research regarding the usefulness of certain advertisements to you. We may share Device Identifier and Usage Information about visitors with third party advertising companies, analytics providers and other vendors for similar purposes. While we may use a variety of service providers to perform advertising and analytics services, some of these companies are members of the Network Advertising Initiative (“NAI”) or the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. You may want to visit http://www.networkadvertising.org/managing/opt_out.asp which provides information regarding targeted advertising and the “opt-out” procedures of NAI members. You may also want to visit or http://www.aboutads.info/choices/, which provides information regarding targeted advertising and offers an “opt-out” by participating companies in the DAA Self-Regulatory Program. Please note opting out through these mechanisms does not opt you out of being served advertising. You will continue to receive generic ads while online.
UPDATING YOUR ACCOUNT
You are responsible for maintaining the accuracy of the information you submit to us. You may review and update the information you have provided to us through your account on the Services. We will make good faith efforts to make requested changes in our then active databases. If you make changes, information may persist internally for administrative purposes and that residual data may remain on backup media or for other reasons. Note, however, that if you have made any public postings on or through the Services, those posts usually will not be removed.
The Services may contain web pages or other features through which you may be able to unsubscribe or modify the e-mail messages or similar communications we send to you. You can choose to opt out of receiving marketing e-mails by following the opt-out instructions provided to you in those e-mails. Please note that we reserve the right to send you certain communications relating to your account or use of the Services (for example, administrative and service announcements) and these transactional account messages may be unaffected if you opt-out from marketing communications. If you sign up to receive SMS or MMS messages that may be offered through the Services, you may unsubscribe from any text messages by replying “STOP.”
THIRD PARTY CONTENT AND OUR CONTENT FOUND OUTSIDE OF THE SERVICES
Certain content on the Services may be hosted and served by third parties and us. The Services may contain links to third party web sites that we do not control. For example, the Services may provide links to third party sites through which you can purchase merchandise, products or services or which link to a product or service offered by a third party. The Services may also contain certain third party applications, such as email, web browser toolbars, wallpapers or other downloads or software applications. These third parties may collect Site Usage Information through the use of their own cookies and web beacons, independently collect data or solicit Personal Information, and may have the ability to track your use of their sites and services.
Certain content you see on the Services is provided by third parties. The Services may link to third party web sites, online services or other content. In addition, you may see our content on third party web sites or elsewhere online. These third parties may independently collect data. We are not responsible for the privacy practices or business practices of any third party.
We take commercially reasonable security measures to protect the Personal Information submitted to us, both during transmission and once we receive it, including encryption of Personal Information transmitted over the Internet. However, no method of electronic transmission or storage is 100% secure. Therefore, we cannot guarantee the security of any information you submit and you do so at your own initiative and risk.
CONSENT TO TRANSFER
We are a United States company. If you are located outside of the United States, please be aware that information we collect will be transferred to and processed in the United States. By using the Services, or providing us with any information, you fully understand and unambiguously consent to this transfer, processing and storage of your information in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen.
CALIFORNIA RESIDENTS – YOUR CALIFORNIA PRIVACY RIGHTS
Under California Civil Code Section 1798.83, California residents who provide us with personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us one time per calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year.
To obtain this information from us, please send your request to the following mailing address:
Two Roads Hospitality
10333 East Dry Creek Road, Suite 450
Englewood, CO 80112
Attn: Electronic Marketing
You must put the statement “Your California Privacy Rights” in the subject field of your writing if you write to us at the designated mailing address. You must include your name, street address, city, state, and zip code. We will respond to you at your mailing address, or at our option, at your e-mail address if you provide it to us. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.