Villatel Privacy Policy

Vacation Capital Group Management LLC., its subsidiaries and affiliates (“Villatel”, “we” or “us”) provide this Privacy Policy (this “Policy”) to inform you of our policies and procedures regarding the collection, use and disclosure of Personal Information we receive from users of www.villatel.com (the “Site] and other products and services (collectively, the “Services”). This Policy also tells you about your rights and choices with respect to your Personal Information, and how you can contact us if you have any questions or concerns. For the purpose of this Policy, “Personal Information” means any information relating to an identified or identifiable individual.

We collect Personal Information from various sources, which are described below. Where applicable, we indicate whether and why you must provide us with your Personal Information, as well as the consequences of failing to do so. If you do not provide Personal Information when requested, you may not be able to benefit from our Services or some features of our Services if that information is necessary to provide you with the Services or if we are legally required to collect such Personal Information. We may collect Personal Information about you directly from you and from third parties, as well as automatically through your use of our Services.

• Registration and Villatel account. When you register with us and create your Villatel Account (“Account”) through the Services or become a Villatel customer (“Customer”) by booking an accommodation at a Villatel property (“Accommodation”), we will ask you for certain Personal Information including your name, contact details (phone number, email address and postal address), date of birth, booking information, and any other information you elect to provide us. We will also process your username and password you create when you register for our Services. We may also ask you to provide a copy of your passport or other official government-issued ID for identity verification purposes at registration. Your payment related information, such as credit card number or billing information, is collected by our third party payment processor on our behalf. We may collect your hashed credit card number in connection with your booking.

We may collect any Personal Information you provide to us as part of the administration and personalization of your account profile (e.g., age, gender and individual preferences). You may voluntarily provide us with information about yourself so that we can personalize your stay with us (e.g., whether or not you have children, whether or not you want to use our additional services such as laundry services etc.).

• Communications. If you contact us directly via email, phone, mail or any other means, we receive information about you (e.g., when you email us, we will receive your email address, the contents of a message or attachments that you may send to us, and any other information you choose to provide). You may also provide us with your reviews of our Services or complete surveys regarding our Services.

• Customer service. If you reach out to us with inquiries or requests, we will keep a record of the communication and how your inquiry or request was handled.

• Cookie information and analytics: When you use our Services, we collect information from you through automated means, such as cookies, web beacons, and web server logs (altogether referred to as “Cookies”). The information collected in this manner includes IP address, browser characteristics, device IDs and characteristics, operating system version, language preferences, referring URLs, and information about the usage of our Services. We use your IP address to derive your approximate location. We also work with analytics providers such as Google Analytics, which use Cookies and similar technologies to collect and analyze information about use of the Service and report on activities and trends. These Services may also collect information regarding the use of other Services, apps and online resources. You can find more information about how we collect information via automated means in the section “How We Use Cookies”.

• Usage of properties. We automatically collect information about your use of Accommodation (e.g., if you return to same Accommodation you have stayed at before, if you gave feedback or if you had any problems during your stay). Where required under applicable law, we will only collect such data with your consent.

• Social media accounts. We may obtain Personal Information about you from third party services, such as Facebook and Twitter, if you link your Account with third-party social media accounts (“Social Media Account”) by either: (i) providing your Social Media Account login information to us through the Service; or (ii) allowing us to access your Social Media Account, as is permitted under the applicable terms and conditions that govern your use of the respective Social Media Account.

• Third party booking services. We may receive your booking information via our partners (e.g., Airbnb, Homeaway, VRBO), such as your name, email address, phone number, information available in your user account with a third party booking service and your Villatel stay information (e.g., information on the Villatel unit you are staying in).

• Other third parties. We may receive additional information about you, such as demographic data, from third parties such as data or marketing partners and combine it with other information we have about you.

We use your Personal Information for the following purposes:

• To operate, provide, and maintain our Services, to provide information that you request, to respond to comments and questions, to provide support and for other customer service purposes.

• To tailor the content and information that we may send or display to you, and to otherwise personalize your experiences while using our Services, including personalizing your Account profile and identifying you as a returning guest to provide products or services to you according to your preferences or restrictions (e.g., by turning on the air conditioner). Where required under applicable law, we will only use your Personal Information for such purposes with your consent.

• To contact you with newsletters, marketing or promotional materials and other information that may be of interest to you relating to Villatel or its partners, via email. Where required under applicable law, we will only send you marketing communications with your consent. We also may use the information that we learn about you to assist us in advertising our Services on third-party websites.

• To link your Account with a third-party account, including a Social Media Account, and to add information from these third-party accounts to your Account and profile page. Depending on the third-party accounts you choose and subject to the privacy settings that you have set in such accounts, we will access, make available and store (if applicable and as permitted by the third-party service and authorized by you) the information in your third-party accounts so that it is available on and through your Account on the Site and Services.

• For our business purposes, such as audits, security, compliance with applicable laws and regulations, fraud monitoring and prevention as well as for quality assurance purposes.

• To facilitate transactions and payments.

• To aggregate or otherwise de-identify data collected through the Service and may use and disclose it for other business purposes after the data may no longer be linked to an identifiable person.

If you are located in the European Economic Area (“EEA”), we only process your Personal Information based on a valid legal ground, including when:

• Consent. You have consented to the use of your Personal Information, for example for marketing purposes or to track your online activities via Cookies and similar technologies.

• Contract. We need your Personal Information to provide you with our Services, for example for account registration and management or to respond to your inquiries.

• Legal obligation. We have a legal obligation to use your Personal Information, for example to comply with tax and accounting obligations, or anti-terrorism laws.

• Legitimate interest. We or a third party have a legitimate interest in using your Personal Information. In particular, we have a legitimate interest in using your Personal Information for product development and internal analytics purposes, and otherwise to improve the safety, security, and performance of our Services. We only rely on our or a third party’s legitimate interests to process your Personal Information when these interests are not overridden by your rights and interests.

Below is an overview of the types of Cookies we and third parties may use to collect Personal Information.

• Operational Cookies necessary for the Site. Some Cookies are strictly necessary to make our Site available to you. You can block these Cookies by changing your browser settings but, because they are strictly necessary for the operation of the Site, we cannot provide you with the Site without this type of Cookies.

• Functional Cookies. Functional Cookies let us operate certain functions of the Site according to your preferences. Deletion of these types of Cookies will result in limited functionality of the Site and less personalized experience.

• Analytical Cookies. We use Cookies for website analytics purposes in order to operate, maintain and improve our Site. We may use our own analytics Cookies or use third party analytics providers such as Google Analytics and Google Tag Manager to collect and process certain analytics data on our behalf. These third parties may also collect information about your use of other websites, apps, and online resources. For instance, Google Analytics helps us understand how users engage with the Site. Like many services, Google Analytics uses first-party Cookies to track user interactions. This information is used to compile reports and to help us improve our Site. The reports disclose website trends without identifying individual visitors. For more information on Google Analytics, click here.

• Advertising Cookies. We work with third-party advertising partners such as Google Ads to show you ads about Villatel that we think may interest you on third party websites and apps. To do so, we and our advertising partners may place and access Cookies through our Site and otherwise collect or access Personal Information collected over time and across different online services. Our advertising partners may also collect information about your use of other websites, apps, and online resources.

Where required by applicable law, we obtain your consent to use Cookies. You can find more information about your rights and choices, and how to opt out of the use of certain Cookies in the section “Your Rights and Choices” below.

We may share your Personal Information under the following circumstances:

• Affiliates. We may disclose the information we collect about you to our affiliates or subsidiaries; however, if we do so, their use and disclosure of your Personal Information will be subject to this Policy.

• 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 but not limited to service hosting, data analysis, customer service, email delivery, auditing, web analytics, payment services and fraud detection services. We require these service providers to safeguard the privacy of Personal Information they process on our behalf.

• Third party booking services. When you book an Accommodation via a third party booking service, we may share your Personal Information with such service in order to manage your booking.

• Property managers. We may share reports with property managers regarding the use of their properties. We may share guest names and dates of stay at the properties for security purposes (e.g., to ensure that the arriving individuals are the guests that booked the Accommodation).

• Business partners. We may share your Personal Information to our business partners who provide you with value-added services such as yoga lessons, laundry services and free time activities in connection with our Services.

• Advertising and analytics partners. We may share non 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 (http://optout.networkadvertising.org/?c=1) or the DAA’s Opt Out Tool (http://optout.aboutads.info/?c=2&lang=EN_ 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 mobile apps.

• Merger, Sale, or Other Asset 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.

• Compliance with laws and law enforcement. If required to do so by law or in the good faith belief that such action is appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

• Consent. We may also disclose information from or about you or your devices with your permission.

• 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. Even if you opt-out of receiving promotional messages from us, you will continue to receive administrative messages from us.

• Do Not Track. There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals.

• European privacy rights. If you are located in the EEA or Switzerland, you are entitled to reach out to us via the contact details in this Policy and ask us for an overview of your Personal Information or ask for a copy. In addition, you may request us to update and correct inaccuracies, delete your Personal Information, restrict processing of your Personal Information, or exercise your right to data portability and to easily transfer your Personal Information to another company. In some cases, you may object to the processing of your Personal Information and where we have asked you for your consent to process your Personal Information, you can withdraw it at any time. We always enjoy hearing from you and appreciate your business. Should you nonetheless have unresolved concerns, you have the right to lodge a complaint with the supervisory authority of your residence, place of work or where the incident took place.

• Your Cookie choices. o Browser settings. If you do not want information collected through the use of Cookies, there is a procedure in most browsers that allows you to automatically decline Cookies or be given the choice of declining or accepting the transfer to your computer of a particular Cookie (or Cookies) from a particular site. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept Cookies, you may experience some inconvenience in your use of the Service. o Google Analytics. You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout. These providers may also collect information about your use of other websites, apps, and online resources.

The Site is not directed to individuals under 13. We do not knowingly collect, maintain, or use Personal Information from children under 13. If a parent or guardian becomes aware that his or her child has provided us with Personal Information in violation of this Privacy Policy, he or she should contact us.

We may display third-party content on the Services. Third-party content may use Cookies, web beacons, or other mechanisms for obtaining data in connection with your viewing of and/or interacting with the third-party content on the Services. This Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the Services links. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

We use reasonable physical, organizational, and technical safeguards that are designed to maintain the integrity and security of information that we collect. Please be aware that no security measures are perfect or impenetrable and thus we cannot and do not guarantee the security or privacy of your data.

We take measures to retain your Personal Information for the period necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or permitted by law. When determining the specific retention period, we take into account various criteria, such as the nature and length of our relationship with you, and mandatory retention periods provided by law and the relevant statute of limitations.

Our Services are operated in multiple countries. The Personal Information we collect is transferred to our affiliates, subsidiaries, service providers and agents, who may be located 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 consent to this Policy followed by your submission of such information represents your agreement to that transfer. If you are located in the EEA, UK or Switzerland, we comply with applicable legal requirements for the transfer of Personal Information to countries outside of the EEA, UK or Switzerland. We may transfer your Personal Information to countries for which adequacy decisions have been issued (e.g., Canada), use contractual protections for the transfer of Personal Information, or rely on third parties’ Privacy Shield certifications, where applicable. You may contact us as specified below to obtain a copy of the safeguards we use to transfer Personal Information outside of the EEA, UK or Switzerland.

We may make changes to this Policy. The “Last Updated” date at the top of this page indicates when this Policy was last revised. If we make material changes, we will notify you through the Services or by sending you an email or other communication. We encourage you to read this Policy periodically to stay up-to-date about our privacy practices. Your use of the Services following these changes means that you accept the revised Policy.

Unless otherwise indicated in this Policy, Vacation Capital Group Management LLC. is the entity responsible, or the “data controller” for the processing of your Personal Information. For privacy inquiries, please contact us at webmaster@villatel.com or at: Vacation Capital Group Management LLC., 750 Lexington Avenue, New York, NY 10022, United States.