Table of Contents
Effective Date: September 23, 2020
Buoy (the “Company” or “us” or “our”) is a software company that offers revenue management tools for the global vacation and short-term rental market. For our products to work, Buoy needs to collect and use certain information about the rental managers and other users of our website located at http://www.buoy.us (the “Website”) and digital services, some of which can be considered Personal Information (as defined below).
• Interact with or use our Website, including when you download materials or resources or request a demo; and
• Use any of our products, services or applications (collectively the “Services”) in any manner.
Your use of our Website and Services is subject to this Policy and the Terms of Service available at this link: [https://buoy.us/terms-of-service/] (the “Terms”). By using our Website and Services, you acknowledge that you have read and understand this Policy and the Terms and that you agree to all of their contents. You do not have to provide Personal Information to us. Please note, however, that if you do not provide certain Personal Information, you may not be able to use or access all or portions of our Website and Services or they may not function as intended.
We will occasionally update this Policy. When we do, we will revise the effective date above. Your continued use of our Website and Services after such changes means you accept the Policy as revised or amended. We encourage you to periodically review this Policy to stay informed about how we collect and process Personal Information. Although we may sometimes send an email or otherwise notify you that we have updated this Policy, we are not required to do so. It is up to you to check the effective date to see if this Policy has changed.
How to Contact Us
If you have any questions or concerns about this Policy, you may contact us by emailing us at: firstname.lastname@example.org
What Personal Information Do We Collect and Process?
In providing our Website and Services, we collect some information that, alone or in combination with other information, can be used to identify you as an individual (“Personal Information”). What Personal Information we collect and process may depend on how and why you interact with us.
Personal Information You Provide To Us:
We collect Personal Information that you choose to send or provide to us. Examples include:
· When you register to use our Services, we collect your contact and account information (including your name, email address, company name, etc.).
· If you contact us, we will keep a record of our correspondence with you that we may retain for auditing and compliance purposes, even if you delete your account on the website.
· If you sign up for a paid service, we will collect financial information you send us to use that service, including your credit card information, billing and mailing address, and other payment-related information.
Personal Information We Collect From Third Parties
We collect Personal Information from third party sources, such as fraud-detection and credit-reference agencies. We also collect property and rental unit information from various third parties and public sources, which can include Personal Information. Please note that we do not intend to collect Personal Information this way. Most, if not all, of the property and rental unit information we collect does not contain Personal Information. If we do happen to collect Personal Information from these third parties, we do not use or disclose it to anyone else.
Personal Information We Automatically Collect:
How and Why We Use Your Personal Information?
Unless you contact us, or create an account, we generally do not use data to personally identify you. We primarily use the information we collect on an aggregate basis to analyze preferences, trends, and traffic patterns to better understand your usage of our website and services, to collect traffic statistics, and to improve our website and services.
We otherwise use your Personal Information for the purposes set out in this Policy, including to improve our Website and Services and to perform our responsibilities under our contract (if any) with you. For example, we may process your Personal Information to:
- Provide and secure our Website and Services;
- Establish and manage accounts;
- To make a record of what products or services customers are interested in and to otherwise improve our products and user experience;
- Provide and streamline customer support, troubleshoot issues, manage our Website and Services, and respond to requests, questions, complaints, and comments;
- Collect and process transactions;
- Communicate with you about our Website and Services, and administer participation in programs, services, and events;
- Conduct market and consumer research and trend analyses;
- Perform accounting, auditing, billing, reconciliation, and collection activities;
- Prevent, detect, identify, investigate, and respond to potential or actual claims, liabilities, prohibited behavior, and criminal activity;
- Comply with and enforce legal requirements, agreements, and policies;
- Achieve purposes for which we provide specific notice at the time of collection;
- Advertise our Website and Services and amend customer product subscriptions; and
- Allow our partners to send you information about services you may be interested in.
We also use information about you where you have given us consent to do so for a specific purpose not listed above (e.g. by filling out a survey). If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place.
From time to time, we will communicate directly with you via newsletters or emails to tell you about new features, promotions, updates, product announcements, and to solicit your feedback about us and our Services, or request information or provide status updates about transactions. Your opt-out options for promotional communications are described in the “What Are Your Rights?” section below. In order to opt-out of communications about transactions, however, you must cancel that transaction as communications may be necessary to complete a transaction.
With Whom Do We Share Your Personal Information?
To the extent we collect and process any Personal Information from you, we only share that information with those necessary to provide our Services, to communicate with you, to advertise or promote our Services, to facilitate changes to or transfers of our business, as required by law, with our partners as described herein, or with your consent.
For instance, we may share Personal Information we collect as follows:
· With affiliated and unaffiliated service providers who help us perform and deliver our Website and Services subject to confidentiality agreements, including: service and sales fulfillment; website management and hosting providers; information technology and security providers; customer service; email and newsletter delivery services; credit agencies, advertisement partners and corporate sponsors; and auditing providers;
· With the appropriate government and law enforcement authorities if necessary to prevent physical, financial, or other harm, including to protect against fraud or credit risk;
· With legal, governmental, or judicial authorities as instructed or required by those authorities and applicable laws, or in relation to a legal activity, such as in response to a subpoena or investigation of suspected illicit or illegal activities, or where we believe in good faith that users may be engaged in illicit or illegal activities, or where we are bound by contract or law to enable a network partner to comply with applicable laws;
· With necessary third parties in connection with, or during negotiations for, an acquisition, merger, asset sale, or other similar business transfer that involves all or substantially all of our assets or functions where Personal Information is transferred or shared as part of the business assets;
· With your consent or at your direction; and
· With persons of your choosing and at your discretion, should the product you are subscribed to allow that functionality.
Additionally, we may share aggregated data that does not identify you with affiliates and third-party business partners.
How Do We Protect Your Personal Information?
While we cannot guarantee your Personal Information is completely secure at all times, we use administrative, organizational, technical, and physical safeguards to protect the Personal Information we collect and process. Our security controls are designed to maintain data confidentiality, maintain data integrity, and give us an appropriate level of access to your data.
Among other things, we use professional third-party service providers and data centers to provide our website and services. Those data centers implement industry-standard measures to protect the security of the Personal Information we collect, such as through use of SSL (Secure Socket Layers), firewalls, and digital certificates to help protect your Personal Information. The financial partners we use that collect and process payment information follow the Payment Card Industry Data Security Standard.While we cannot guarantee your Personal Information is completely secure at all times, we use administrative, organizational, technical, and physical safeguards to protect the Personal Information we collect and process. Our security controls are designed to maintain data confidentiality, maintain data integrity, and give us an appropriate level of access to your data.
Among other things, we use professional third-party service providers and data centers to provide our Website and Services. Those data centers implement industry-standard measures to protect the security of the Personal Information we collect, such as through use of SSL (Secure Socket Layers), firewalls, and digital certificates to help protect your Personal Information. The financial partners we use that collect and process payment information follow the Payment Card Industry Data Security Standard.
The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
While we have employed security technologies and procedures to assist safeguarding your Personal Information, no system or network can be guaranteed to be 100% secure. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of user information at any time. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website or any other Services.
How Long Do We Keep Your Personal Information?
We keep your Personal Information in line with set periods of time calculated using the following criteria:
- How long you have been a user of our Website and Services, the types of services you have used, and when you will stop being a user;
- How long it is reasonable to keep records to show we have met the obligations we have to you and by law;
- Any time limits for making a claim;
- Any periods for keeping information which are set by law or recommended by regulators, professional bodies or associations;
- Our standard backup and disaster recovery retention periods; and
- Any relevant retention periods required for proceedings that may be initiated.
If you wish to be deleted entirely from our records, please contact use as set forth above. Submitting a verified request will cause us to delete the account containing the Personal Information, but it will not cause us to delete (i) any information relating to a transaction that was initiated or completed (which we may retain for accounting, compliance and auditing purposes), (ii) our security logs (which we retain for a limited period of time to help monitor and maintain security), (iii) your communications with us (which we may also retain for compliance and auditing purposes), or (iv) our backups and archives which we maintain for disaster recovery and business continuity purposes. If you decide to delete your account, we may retain your Personal Information up to 90 days following your account’s deletion date. If you would like more information about how long we will keep your information, please contact us as specified above.
What Are Your Rights?
Your Rights to Opt Out of Marketing
You may choose not to receive marketing communications from us by clicking on the unsubscribe link in our promotional emails or by contacting us as described above. If you provide us with inconsistent privacy preferences (for example, by indicating on one occasion that we may provide you with marketing offers and on another occasion that we may not), we will treat it as if you opted out to receive our marketing communications.
Your Right to Access
You have the right to request copies of your personal data from the Company. We may charge you a small fee for this service.
Your Right to Rectification
You have the right to request that the Company correct any information you believe is inaccurate. You also have the right to request the Company completes the information you believe is incomplete.
Your Right to Erasure
You have the right to request that the Company erase your personal data, under certain conditions.
Your Right to Restrict Processing
You have the right to request that the Company restrict the processing of your personal data, under certain conditions.
Your Right to Object to Processing
You have the right to object to the Company’s processing of your personal data, under certain conditions.
Your Right to Data Portability
You have the right to request that the Company transfer the data that we have collected to another organization, or directly to you, under certain conditions.
Your California Privacy Rights
For residents of California that access our website or otherwise transmit Personal Information to us, we do not sell your Personal Information to third parties. You have the right to request access to, changes to, or the removal of your Personal Information in accordance with applicable laws by contacting us as indicated above. We will not discriminate against you if you choose to exercise any of your rights under California law. Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of Personal Information which we share with our affiliates and third parties for marketing purposes, and providing contact information for such affiliates and third parties. If you are a California resident and would like a copy of this notice, please submit a written request to the following address: [111 W 7th St Los Angeles CA 90014]. We will make every effort to promptly respond to your request.
Links to Other Websites
Our website or services may contain links to other websites that we do not own or control. We are not responsible for the data collection practices of any of these other websites. You will not hold us responsible for any aspect of these other websites, including their content, privacy policies, or anything else. You must use your own discretion when you go to other websites. We encourage you to carefully review the privacy policies applicable to any website or service you visit other than our Website and Services before providing any Personal Information on them.
How Do We Respond to “Do Not Track” Signals?
We do not process or respond to web browsers’ “do not track” signals or other similar transmissions that indicate a request to disable online tracking of users who use or visit our website. You may, however, disable certain tracking as discussed above (e.g., by disabling cookies). Please consult the “Help” section of your internet browser for more information.
Policy Regarding Information Obtained From Children
Our website and services are directed at adults and users of our services are required to be at least 18 years of age (or have the permission and supervision of a responsible parent or legal guardian). We do not knowingly collect Personal Information from children under the age of 13. If we learn that we have collected Personal Information from a child under the age of 13 on our Website or through our Services, without the consent of the child’s parent or guardian, we will delete that information. If you believe that we may have collected any such Personal Information on our Website or through our Website and Services, please notify us at as specified above.