This Privacy Policy ( “Privacy Policy”) specifies how information about you (“User”, “you”, or “your”) is collected, used and disclosed by VROOMRes, LLC (“VROOMRes”, “we”, “us”, or “our”) when you use the VROOMRes website located at www.vroomres.com (“Site”) or any tools and services provided in connection with the Site. Notwithstanding the prior definition, the term “VROOMRes” shall also include its affiliates, subsidiaries, and its and their investors, officers, directors, employees, agents, representatives and assigns. This Privacy Policy is intended for individuals located in the United States in order to help you understand how we collect and use the information that you share with us and to help you make informed decisions about your personal information when using the Site. Capitalized terms not otherwise defined in this Privacy Policy shall have the meaning ascribed to them in our Terms of Service. If you are visiting this Site from the European Union, Switzerland or European Economic Area please click here.

By registering for, accessing, visiting, browsing, using or attempting to interact with or use any part of this Site, you agree that you have read, understand and agree to be legally bound and to abide by this Privacy Policy and that you read, understand, and agree to the Terms of Service found at www.VROOMRes.com/legal.

1. Information Collected

1. Personal Information. When accessing the Site generally, you are not required to provide any Personal Information. “Personal Information” is information that can be used to contact or identify you. The collection and types of Personal Information may vary depending on how it is provided to us, and it may include, but is not limited to, the following categories: name, physical address, zip code, email address, phone number, and demographic data (such as age or gender) together with all other information you provide to, integrate, upload, allow access to, or permit interaction with the Site. We may collect other Personal Information that we receive from you through your communication with us (such as subscribing to electronic newsletters).
2. Non-Personal Information. In addition to any information that you choose to provide us, we and our Third Party Service Providers reserve the right to collect Non-Personal Information when you use our Site. “Non-Personal Information” is information that cannot be used to contact or identify you and is not linked to information that can be used to contact or identify you; this includes passively collected information about your activities using our Site, such as usage data, URL tracking information, your IP address, and information about your web browser to the extent that information is not considered Personal Information. Non-Personal Information further includes aggregate non-identifiable information that may relate to you but cannot specifically identify you.
3. Information collected by Cookies. We use various technologies to collect information about you, and this may include sending cookies to your computer or mobile device, among others. Cookies are small data files stored on your hard drive or in device memory that help us to improve the Site and your experience, see which areas and features of the Site are popular, count visits and track user activity among other things.
4. Information collected by Web Beacons. We may use other industry standard technologies like web beacons or tracking pixels to count the number of users that visit a page on the Site that includes these web beacons. Web beacons are used to report on site traffic and are used to analyze the effectiveness of advertising campaigns and how Users interact with the Site. We may also rely upon third parties to assist with the use and implementation of web beacons.
5. Information we collect from other services. We may also obtain information from other sources and combine that with information we collect through the Site; this information may include, but is not limited to, analytics, identity verification services, credit bureaus, mailing list providers, or other publicly available sources.

2. Use of Information

We may use your Personal Information and Non-Personal Information to do any of the following:

1. Provide, troubleshoot, maintain and improve the Site;
2. Provide and deliver the products and services you request, process payments and other transactions and send you related information, including without limitation confirmations and invoices;
3. Send you technical notices, updates, security alerts and support and administrative messages;
4. Respond to your comments, questions and requests, and provide customer service;
5. Communicate with you about products, services, offers, promotions, rewards, and events offered by VROOMRes and others, and provide news and information we think will be of interest to you;
6. Authenticate your identity and pre-populate forms;
7. Monitor and analyze data, trends, usage and activities in connection with the Site; measure the effectiveness of advertising, content, features and activities, and perform other data analytics;
8. Personalize and improve the Site and deliver and display targeted advertisements, content or features in the Site; and
9. Carry out any other purpose for which the information was collected or as otherwise described in this Privacy Policy.

3. Sharing of Information

In addition to using the information collected by VROOMRes for the purposes described in this document, we may also share your information with various third parties, as described below.

1. Personal Information.
   If you are a User your Personal Information posted in the Site may be available to other Users. This information may include, but is not limited to: event posting, profile information such as name, city, state, contact information such as phone number or e-mail, and a picture of you. In addition, your Personal Information may be shared with property managers, property owners, and Third Party Service Providers and/or companies that perform services for us, such as analyzing customer data, providing marketing assistance, providing reservation and booking assistance and processing credit card payments. They have access to Personal Information as needed to perform their functions, but may not disclose your Personal Information for other purposes.
2. Non-Personal Information.
   ii. This Privacy Policy dos not limit our use or disclosure of your Non-Personal Information, such as information passively collected from your computer via cookies, web beacons, or standard logging of website activity. If you do not wish to share this information with VROOMRes, then you should take steps to limit the passive collection of data about your activities on our site, for example, by changing your browser settings to disable cookies. We reserve the right to use and disclose such Non-Personal Information, as well as any other Non-Personal Information we collect, with other third parties at our discretion.
3. Business Transactions.
   iii. In the event we go through a business transition such as a merger, acquisition by another company or sale of all or a portion of our assets, your Personal Information may be among the assets transferred. You acknowledge and consent that such transfers may occur and are permitted by this Privacy Policy, and that an acquirer or that acquirer’s affiliates may continue to process your Personal Information as set forth in the Privacy Policy.
4. Disclosure By Law.
   iv. We may disclose any information, both Personal Information and/or Non-Personal Information, you provide if required to do so by law, at the request of a third party, or if we, in our sole discretion, believe that disclosure is reasonable to comply with the law, requests or orders from law enforcement, or any legal process or to protect or defend VROOMRes or a third party’s rights to property, or protect someone’s health or safety.
5. Electronic Communications.
   When you visit the Site or send or accept electronic messages through the Site, you are communicating with us electronically, and as a result, you consent to receive communications from us electronically. We may communicate with you by email or other authorized form of electronic message or by posting notices on the Site. You agree that all agreements, notices, disclosures and other communications that we provide to you electronically satisfy any legal requirement that such communications be in writing. You further agree that any notices provided by us electronically are deemed to be given and received on the date we transmit any such electronic communication as described in the Terms.

4. 4. Your Choices

You have a right to withdraw your consent to receive electronic communications at any time, and may request a paper version of any electronic communication. To request a paper copy of an electronic communication, you may do so by contacting us in accordance with the ‘Contact Us’ section below.

You may review, correct and update certain Personal Information displayed on your profile or within your account, if applicable, by logging in to your account on the Site and accessing your account settings or Personal Information and updating the applicable fields, or by contacting VROOMRes through the ‘Contact Us’ section below.

5. 5. Security of Information

VROOMRes takes reasonable measures in an attempt to help protect your Personal Information from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. However, no data transmitted over or accessible through the Internet can be guaranteed to be 100% secure, and VROOMRes does not represent or warrant that your information will be completely secure, including without limitation from misappropriation by hackers or from other nefarious or criminal activities, or in the event of a failure of computer hardware, software, or telecommunications network.

6. 6. Links to Third-Party Sites

The Site may contain links to Third Party Service Providers, or other websites. Any information you provide on those sites are provided directly to the owner of that website and is subject to that website’s terms of use, privacy policy, and other conditions. Our Privacy Policy does not apply to any linked websites. We are not responsible for the content, privacy, or security practices of the linked websites.

7. 7. Changes to Our Privacy Policy

We reserve the right to change, modify, or update this Privacy Policy from time to time. The most current version of the Privacy Policy will govern our use of your information and will always be available at www.VROOMRes.com/privacypolicy If we change this Privacy Policy in ways that materially affect how we use your Personal Information, we will provide you with notice thereof and advise you of choices you may have as a result of those changes. Your continued use of the Site after any changes become effective, indicates your agreement to the changes.

8. 8. Minors

The Site is not intended to be used by persons under the age of eighteen (18) years old. VROOMRes does not knowingly collect or solicit Personally Information from children under the age of eighteen (18). If you are under the age of eighteen (18) years old, please do not use the Site or any of the services offered by VROOMRes. If you believe VROOMRes has any information from or about anyone under the age of eighteen (18) please contact us in accordance with the ‘Contact Us’ section below.

9. 9. Release

By using the Site, you consent and agree to the terms set forth in this Privacy Policy and acknowledge the following:

1. We have clearly, conspicuously and completely informed you of any and all potential uses of your information by us, our authorized third parties;
2. We will not access, use or distribute your information if you take any action to indicate that you no longer want your information to be used or accessed for any reason, including revoking your consent in writing to the address listed in the ‘Contact Us’ section below.
3. We will not modify, manipulate or change your information; and
4. We will not use your information in furtherance of criminal, fraudulent, or other unlawful activity.

11. 11. Contact Us

E-mail: info@vroomres.com
Call: 843-808-8766
Address: 514 Mill Street, Suite F, Mount Pleasant, SC 29464

VROOMRes Privacy Shield Privacy Policy for Data Subjects located in the European Economic Area and Switzerland.

VROOMRes LLC (“VROOMRes” or “Company”) complies with the EU-US Privacy Shield Framework and the Swiss – US Privacy Shield Framework set forth by the US Department of Commerce regarding the collection, use, and retention of Personal Data, as defined under the European Union’s General Data Protection Regulation, from European Union member countries and Switzerland, respectively.  VROOMRes has certified to the Department of Commerce that it adheres to the Privacy Shield Principle (the Principles”).  If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/

Scope
This Privacy Shield Privacy Policy (the “Policy”) sets forth the privacy principles that VROOMRes follows when it receives and processes Personal Data from Data Subjects located in the European Economic Area (“EEA”) and Switzerland. For purposes of this Policy, “Personal Data” means information about an identified or identifiable individual that is received by VROOMRes in the U.S. from the EEA or Switzerland and recorded in any form. The types of Personal Data we may obtain includes the following:

1. Contact information (such as name, postal or e-mail address, and phone or fax number)
2. Business contact information (such as job title, department and name of organization, business address, e-mail address, mobile telephone number)
3. Country of origin information (from which country you are accessing the Web Site)
4. Usernames and passwords used to access VROOMRes resources
5. Financial information (such as financial account information used for payment purposed and/or information that may be contained in a consumer report)
6. Contact information for referrals or other individuals you would like us to contact
7. Content you provide (such as photographs, articles and comments)
8. Employment information (such as employment history, employee number, performance appraisals, salary and benefits)
9. Mobile device unique identifier
10. Social Media identifier (such as Facebook, LinkedIn or Twitter Identification)
11. Geo-location data
12. Other information (such as language preference)

VROOMRes’ Compliance with the Privacy Shield Principles
VROOMRes employees located in the U.S. may process Personal Data for VROOMRes customers, prospective customers, third party service providers and VROOMRes’ employees and prospective employees located in the EEA or Switzerland. VROOMRes may process Personal Data in the course of business operations and as more fully described above and in VROOMRes’ Privacy Policy. VROOMRes will apply the following Privacy Shield Principles to Personal Data physically or remotely transferred from the EEA or Switzerland to the U.S.

ACCESS
Data Subjects have the right to access the Personal Data an organization holds about them. If such Personal Data is inaccurate or processed in violation of the Privacy Shield Principles, a Data Subject may also request that Personal Data be corrected, amended, or deleted.

When VROOMRes receives Personal Data, it does so on behalf of the individual submitting such Personal Data.  To request access to, or correction, amendment or deletion of, Personal Data, Data Subjects should contact VROOMRes’ Data Protection Officer.  VROOMRes will cooperate with all reasonable requests to assist Data Subjects to exercise their rights under the Privacy Shield.

CHOICE
Data Subjects have the right to opt out of (a) disclosures of their Personal Data to third parties not identified at the time of collection or subsequently authorized, and (b) uses of Personal Data for purposes materially different from those disclosed at the time of collection or subsequently authorized.  Data Subjects who wish to limit the use or disclosure of their Personal Data should submit that request to VROOMRes’ Data Protection Officer.  VROOMRes will cooperate with the Data Subjects’ instructions regarding Data Subjects’ choices.

SECURITY
VROOMRes maintains reasonable and appropriate measures to protect Data Subjects from loss, misuse and unauthorized access, disclosures, alterations and destruction taking in to account the risk involved in the processing and the nature of Personal Data. Unfortunately, no site, server or database is completely secure or “hacker proof.” We therefore cannot guarantee that information about you will not be disclosed, misused or lost by accident or by the unauthorized acts of others.

PURPOSE LIMITATION AND DATA INTEGRITY 

VROOMRes limits collection of Personal Data to that which is necessary to accomplish the purposes disclosed to Data Subjects and compatible purposes. VROOMRes is responsible for the processing of Personal Data consistent with such purposes.  VROOMRes will process Personal Data only in compliance with applicable law and, to the extent consistent therewith, in accordance with the Data Subjects’ instructions.

VROOMRes will ensure that [(a) Personal Data maintained by VROOMRes is accurate, complete, current and reliable for its intended uses; and (b) Personal Data is retained only for as long as is necessary to accomplish the legitimate business purposes disclosed to the Data Subject and for any compatible purposes. VROOMRes will cooperate with reasonable requests for assistance in meeting these obligations.

VROOMRes will request only the minimum amount of information required to perform the applicable services and will retain such information only for as long as necessary to provide the services or for compatible purposes, such as to provide additional services, to comply with legal requirements, or to preserve or defend VROOMRes’ legal rights.

ONWARD TRANSFER
VROOMRes will not disclose Personal Data to a third party, except as stated below:

VROOMRes may disclose Personal Data to subcontractors and third-party agents. Before disclosing Personal Data to a subcontractor or third-party agent, VROOMRes will obtain assurances by contractual agreement from the recipient that it will: (i) transfer such data only for limited and specified purposes; (ii) ascertain that the subcontractor or third-party agent is obligated to provide at least the same level of privacy protection as is required by the Principles; (iii) take reasonable and appropriate steps to ensure that subcontractors and third-party agents effectively processes the personal information transferred in a manner consistent with the organization’s obligations under the Principles; (iv) require subcontractors and third-party agents to notify the organization if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the Principles; (v) upon notice, including under (iv), take reasonable and appropriate steps to stop and remediate unauthorized processing; and (vi) provide a summary or a representative copy of the relevant privacy provisions of its contract with subcontractors and third-party agents to the Department of Commerce upon request.

VROOMRes may also be required to disclose, and may disclose, Personal Data in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements or in the event of a merger or acquisition. To the extent permitted, VROOMRes will inform Data Subjects before making such disclosure and provide it with a reasonable opportunity to object to such disclosure.

In cases of onward transfer to third parties of data of EU and Swiss individuals received pursuant to the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield, VROOMRes is potentially liable.

RECOURSE, ENFORCEMENT & LIABILITY
In compliance with the EU-US and Swiss-US Privacy Shield Principles, VROOMRes commits to resolve complaints concerning its processing of Personal Data in accordance with the Privacy Shield Principles.

Any Data Subject who has a complaint about VROOMRes’s processing of his/her Personal Data should first contact VROOMRes’s Data Protection Officer by emailing data.protection@VROOMRes.com or by calling 843-808-8766.

VROOMRes has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles and Swiss-US Privacy Shield Principles to an independent recourse mechanism operated by JAMS (“JAMS”). If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by VROOMRes, please contact or visit https://www.jamsadr.com/eu-us-privacy-shield for more information and to file a complaint at no cost to you. In addition to the above dispute resolution mechanisms, Data Subjects may invoke binding arbitration if their complaint is not resolved by the JAMS or by the Department of Commerce after referral from the relevant data protection authority in the EEA or Switzerland. For more information about binding arbitration, visit https://www.privacyshield.gov.

VROOMRes is subject to the investigatory and enforcement powers of the Federal Trade Commission.

For More Information
Data Subjects with questions about how VROOMRes processes Personal Data should contact VROOMRes’s Data Protection Officer can be contacted email at data.protection@VROOMRes.com or by calling 843-808-8766.

This policy is executed in English and has been translated into other languages. In the event of any conflict or discrepancy between the English language version and a translated version, the English language version of this policy shall control.

Changes to this Privacy Policy
VROOMRes may revise this Policy at any time.  If VROOMRes decides to materially change this Policy, VROOMRes will post the revised Policy at this location.

Effective Date December 31, 2019.