● As you access our website, e-mails, social media pages or mobile applications that we own or control (hereinafter “our sites”)
● Through your communications and other interactions with us both online and offline (hereinafter “other interactions”)
(The foregoing categories hereinafter collectively referred to as the “services”)
Our site may contain links to the websites of third parties, as well as to social media platforms such as Facebook (hereinafter “third-party sites”) that we do not control. These third-party sites may independently collect information, including personal information, from you and, in some instances, provide us with information about your activities on those sites. We are not responsible and have no liability for the privacy policies or practices of third-party sites. We recommend that you review the privacy policies of each third-party site you visit.
2. INFORMATION WE COLLECT
We may collect a variety of information about you and the examples we provide here are illustrative rather than a complete list of our practices. We may collect the personal information and non-personal information we need to process your reservation requests and to provide the services you request from us as well as for our operational and marketing uses in connection with such services as more specifically described in the How We Use Your Information section.
We collect Personal Information such as:
● Date of Birth
● Contact information, such as postal address, email address and telephone number
● Credit and debit card number or other payment data
● Driver’s license or other government-issued identification data
● Data about family members and companions, such as names and ages of children
● Data about prior property visits and other interactions, such as special service requests and your comments and feedback
● Data about your personal preferences, such as your interests, activities and language
● Data about your marketing preferences such as the type of marketing materials you wish to receive and the method of their delivery
● Images and video from security cameras located in common areas at our Veteran Benefit Consulting Group property and audio information from your telephone communications with us which may be recorded
We collect Non-Personal Information such as:
● Browser and device data
● Data collected through cookies, pixel tags and other technologies
● Demographic data
3. HOW WE COLLECT YOUR INFORMATION
We collect personal information in a variety of ways, including:
Information You Provide. We may collect personal information that you provide to us while using our sites or services including:
● your subscription to our newsletter, emails, or other communications from us
● your providing or submitting comments, suggestions, experiences, or other content to us, including your participation in surveys
● your posting on our sites and our pages or accounts on any third-party sites, including social media platforms such as Facebook
Information Collected Automatically. When you access or use our sites, we may automatically receive information about your visit including:
● Browsing Information: such as your web browser type, access times, pages viewed, your IP address and the page you visited before navigating to our sites.
● Device Information: including the computer or mobile device you use to access our sites, including your IP address, the hardware model, operating system and version, unique device identifiers and mobile network information.
● Location Information: if you enable location services on your device, we may collect information about the location of your device when you access or use our sites. You may opt-out from allowing us to have access to your location data by adjusting the permissions in your devices, though some features of our sites may not function properly if use or availability of location data is impaired or disabled.
Information Collected by Cookies and Other Tracking Technologies. We use various technologies to collect information, including:
By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. You can opt out of our advertising service provider(s) and other companies tracking cookies by visiting the Digital Advertising Alliance currently located at: http://www.aboutads.info/choices/ or the NAI currently located at: http://www.networkadvertising.org/choices/.
● Clear Gifs/Web Beacons: when you use our sites, we may employ clear gifs (also known as web beacons) which are used to track your online usage patterns. In addition, we may also use clear gifs in HTML-based emails sent to our users to track which emails are opened and which links are clicked by recipients.
● Analytics Information: we may use third-party analytics tools, such as Google Analytics, to help us measure traffic and usage trends for our sites. These tools collect information sent by your browser or mobile device, including the pages you visit and other information that assists us in improving our sites.
To learn more about how to opt out of Google’s use of the Google Analytics cookie, visit the Google Analytics Opt-Out Browser Add-on at https://tools.google.com/dlpage/gaoptout.
Information We Collect from Third Parties. We may receive information about you from third parties, including without limitation to identity verification services, fraud detection service providers, credit bureaus, mailing list providers and publicly available sources. If you access our pages on third-party social media sites, we will have access to certain information from that site, such as your name, account information and friends’ lists, in accordance with the authorization procedures determined by such social media sites. We may also engage independent third parties such as marketing, surveys, or software suppliers to collect information to assist us.
4. HOW WE USE YOUR INFORMATION
We collect your information, including personal information, for the following purposes:
● To provide you with the services you request.
● To provide you with a customized and optimized experience
● For security and verification purposes, including to protect the rights, privacy, safety or property of our business, our sites, you or others
● To process payments and complete your transaction
● To communicate with you regarding our products, services, promotions, news, events, and other updates we think may be of interest to you
● To respond to your inquiries, comments, or postings
● To administer our events
● To comply with a legal, tax, accounting, anti-money laundering, legal order, or other obligations which we are subject
● To establish, exercise or defend our legal rights
● For internal operations such as conducting research and analysis in order to enhance our services, improve and customize our sites, optimize our marketing efforts and measure the overall effectiveness of our advertising, content, programming and other activities.
● To investigate or settle inquiries or disputes
● To address and remediate technical issues and bugs
● For direct marketing purposes
● To manage our business
● To enforce our terms and conditions
5. DISCLOSURES OF PERSONAL INFORMATION
Your personal information will not be used in a way that is incompatible with the purpose for which it was collected or as authorized by you. We are committed to sharing personal information only when needed for a legitimate business or legal purpose. We may share information about you with our affiliates in order to better serve you and to offer you worthwhile products and services.
Your personal information may be used and/or disclosed in connection with any purpose related to any of the following:
Payment Processors: if you pay for use of our services, we will use your personal information to process payments and confirm your transactions.
Public Authorities: in certain instances, it may be necessary for us to disclose your personal information to public authorities or as otherwise required by applicable law. No personal information will be disclosed to any public authority except in response to:
● A subpoena, warrant or other process issued by a court or other public authority of competent jurisdiction
● A legal process having the same consequence as a court-issued request for data
● Where such disclosure is necessary for us to enforce our legal rights, detect or prevent fraud or security concerns, and protect public safety
Our Employees and Agents: to the extent necessary to fulfill our obligations to you we will share your information, including certain personal information, among our employees, to provide you with the services you have requested, for customer satisfaction, market research purposes and to otherwise help us improve our services.
Direct Marketing Uses and Disclosures: we may send you direct marketing communications and information about products and services offered. We may aggregate your personal data and use it to develop marketing programs and service offerings that we believe may be of interest to you. We may send these to you by email, by text message or by mail. We may also share your personal data with our licensees, affiliates and business partners for their direct marketing communications. We will not charge you for such calls or texts. Your mobile service provider will charge you according to the applicable plan to which you subscribe.
Your personal data may be used for the above marketing purposes, although you can choose to limit or restrict our mailings and our share of your data for these uses by following the instructions below:
You may opt out of receiving marketing communications from us and our business partners at any time by responding via the channel in which you received the marketing communication, or by contacting us.
We will not share your personal information with other companies for their marketing use unless you actively consent to such sharing. However, denying consent to information sharing may not prohibit sharing for non-marketing and operational purposes such as customer service or assisting with your requested services.
You can unsubscribe from emails from us by clicking the ‘unsubscribe’ link on the footer of the email communication you have received. Although we aim to process your choices promptly, you may still receive marketing communications prepared before we received your request to unsubscribe. If you choose not to receive marketing messages from us, you may not be able to receive certain benefits, such as promotions.
We may also work with third-party companies that use their tracking technologies (including cookies and pixel tags) on our websites in order to provide tailored advertisements on our behalf and on behalf of other advertisers across the Internet. These companies may collect information about your activity on our sites and your interaction with our advertising and other communications and use this information to determine which ads you see on third-party websites and applications.
We are permitted by law to share all the information we collect, as described above: (1) with companies that perform marketing services on our behalf, and (2) with other nonaffiliated third parties such as third parties that assist us with processing or collecting payments on your account. Please be advised that the preferences you express as described below will not apply to the sharing of information with these third parties.
Unless you request otherwise, we may share all the information we collect, as described above, with other third parties, such as firms that offer products and services of interest to our customers.
If you do not wish to receive such emails, mailings or telephone calls, you may request that we not share personal information about you with such third parties by emailing our team. We will implement your request within a reasonable time after we receive it.
6. CALIFORNIA RESIDENTS: CALIFORNIA PRIVACY RIGHTS
Under the California Consumer Privacy Act, California residents have certain privacy rights regarding their personal information.
● Identifiers such as name, alias, date of birth, postal address, email address, telephone number, passport number, driver’s license number or other governmental-issued identification data, social security number, internet protocol address, MAC address and names and ages of your family members and companions.
● The following categories of personal information described in California Civil Code §1798.80(e): (1) the personal information listed in the preceding bullet point as “identifiers,” (2) signatures, (3) demographic data such as gender, language preference, employment and employment history, (4) payment information such as bank account number, credit card number, debit card number or portions thereof, (5) information you provide or that we record in connection with customer support calls or complaints, and (7) other information that identifies, relates to, describes, or is capable of being associated with, a particular individual that we describe in the Information We Collect section.
● Characteristics of protected classifications under California or federal law, such as age and marital status.
● Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with our sites or advertisements such as data collected through cookies, pixel tags and other technologies.
● Geolocation data such as physical location or movements relating to your computer or device when you interact with our sites.
● Audio, electronic, visual, or similar information including images and video from security cameras located in common areas at our property, audio information from your telephone communications with us which may be recorded, and electronic information in the form of internet or other electronic network activity information as described above.
● Professional or employment-related information such as current or past job history.
● Inferences drawn from (1) the information we collect when you visit our sites, (2) information we collect, including from third parties, regarding content and other data posted on the internet, and (3) information about consumer preferences and behavior that we collect on our sites from third parties in order to create a profile about a consumer reflecting the consumer’s preferences, characteristics, predispositions, or behavior.
Sale of Personal Information. We do not sell personal information.
YOUR CALIFORNIA PRIVACY RIGHTS
If you are a California consumer, you have the following rights. We will honor requests received to the extent required by applicable law and within the time provided by law.
Right to Access and Information regarding Personal Information. You have the right to request that we disclose the following to you, in each case in the 12-month period preceding your request:
● the categories of personal information we have collected about you;
● the categories of sources from which the personal information is collected;
● our business or commercial purpose for collecting or selling personal information;
● the categories of third parties with whom we share personal information;
● the specific pieces of information we have collected about you;
● the categories of personal information about you, if any, that we have disclosed for monetary or other valuable consideration and the categories of third parties to which we have disclosed the information, by category or categories of personal information for each third party to which we disclosed the personal information; and
● the categories of personal information about you that we disclosed for a business purpose.
We will deliver personal information that we are required by law to disclose to you in the manner required by law within 45 days after receipt of a verifiable request, unless we notify you that we require additional time to respond, in which case we will respond within such additional period of time required by law.
Right to Deletion of Personal Information. You have the right to request that we delete personal information about you that we have collected. However, there are several exceptions when we shall not be required to delete personal information, including but not limited to, if the personal information is necessary in order for us to:
● Complete the transaction for which the personal information was collected;
● Provide a good or service requested by the consumer, or reasonably anticipated within the context of a business’ ongoing business relationship with the consumer;
● Perform a contract between us and the consumer;
● Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
● Debug to identify and repair errors that impair existing intended functionality;
● Exercise free speech, ensure the right of another consumer to exercise that consumer’s right of free speech, or exercise another right provided for by law.
● Comply with the California Electronic Communications Privacy Act (Cal. Penal Code §1546 et seq.);
● Engage in public or peer-reviewed scientific, historical, or statistical research in the public interests that adheres to all other applicable ethics and privacy laws;
● Comply with a legal obligation;
● Make other internal and lawful uses of the personal information that are compatible with the context in which the consumer provided the information.
Right to Opt-Out. You have the right to opt out of the disclosure of your personal information to third parties for monetary or other valuable consideration. To opt-out, please visit: Contact Page
Right to Non-Discrimination. You have the right to not be discriminated against because of your exercise of any of the foregoing rights or any other rights under the California Consumer Privacy Act, including by:
● Denying you goods or services;
● Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
● Providing you a different level or quality of goods or services; or
● Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
We may, however, charge different prices or rates, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to Veteran Benefit Consulting Group by your Personal Information.
REQUEST TO EXERCISE YOUR RIGHTS
You may request to exercise the foregoing rights by:
● Emailing us at email@example.com and submitting a request,
● Submitting a request through Contact Page or
● Calling us toll-free at 1-866-433-6165
Please note that we may take steps to verify your identity before granting you access to information or acting on your request to exercise your rights, as required or permitted by law. We may limit our response to your exercise of the above rights as permitted by law. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
7. CHILDREN’S PRIVACY
Our sites are not intended for use by children under 13 years of age. Although most portions of our sites are directed to general audiences, it is our policy to not knowingly collect, use, or disclose personal information about visitors who are under 13 years of age. If we become aware that we have collected such information without parental or guardian consent or other than in a manner authorized by law, we will promptly delete such information from our servers.
8. HOW WE MANAGE AND STORE YOUR PERSONAL INFORMATION
We may hold your personal information in either electronic or hard copy form. If you provide information to us electronically we may retain this information in our computer systems and databases. This includes computer software programs, internet servers, and hosted internet solutions provided by third parties. If you provide information to us in hard copy (paper), this information may be retained in our files and a copy may be made to our electronic files.
9. HOW WE PROTECT YOUR PERSONAL INFORMATION
We use industry standard security measures to safeguard and protect your information. This includes taking reasonable safeguards to protect your personal data from misuse, loss, unauthorized access, modification or disclosure. However, no method of internet transmission or data storage can provide guaranteed protection to your information. We also request that our third-party service providers use appropriate security measures to protect your information from unauthorized access or use.
We try to strike a balance between the security of your personal data and your convenience. As a result, we may sometimes use a method of communication that is less secure than a less convenient alternative. For example, but not limitation, we may send you an email or text message in an unencrypted form because many of our customers are unable to access encrypted (coded) emails or messages. This means that our message, if misrouted or intercepted, could be read more easily than encrypted messages. For this reason, please do not include confidential information, such as your credit card number or account passwords, in any e-mail or text message you send to us or on any posting you make to a public area of a third party social network page, especially since any such posting immediately becomes public.
10. USE OF OUR IMAGES
All images and/or pictures of properties featured on our sites are our property, and any unauthorized reproduction, appropriation, or distribution of the aforementioned images and/or pictures is prohibited.
11. SUBMISSIONS AND USER GENERATED CONTENT
Unless governed by separate terms identified at the time of submission, all comments, ideas, reviews, photos, or videos you communicate or submit to us (collectively “submissions”) will be considered non-confidential and non-proprietary. We shall have no obligation of any kind with respect to such submissions and shall be free to use and distribute submission for any purposes, without limitation of any kind. If you upload your own content to our sites, please be advised that this content will be accessible by the public at large, and not just by us. Therefore, you should never upload any content or personal information that you do not want others to have access to. You should not upload photos or videos that include people that you do not know and/or have their permission to use.
12. YOUR CHOICES IN HOW WE USE YOUR INFORMATION
While we may contact you with offers and information concerning our services, you always have the choice not to receive such items. You may contact us as described in the Contact Us section to communicate your marketing preferences and request to be removed from marketing lists.
14. NOTICE OF INFORMATION-SHARING DISCLOSURE
You have the right to request a disclosure from Veteran Benefit Consulting Group regarding how it shares personal information with other businesses for direct marketing purposes. To request an Information-Sharing Disclosure, please email firstname.lastname@example.org with the subject line “California Information-Sharing Disclosure.” We will provide, within 30 days of the receipt of the request and at no cost, the Information-Sharing Disclosure to the requesting email address. We will only provide one Information-Sharing Disclosure each calendar year.
15. UPDATING YOUR INFORMATION
You may update your information at any time via the Contact tab on our website.
You may update your information at any time by contacting our team at email@example.com We will implement your request within a reasonable time after we receive it. To protect your privacy and the security of your personal data, we may ask you to verify your identity before granting you access or making changes to the data we store about you.
16. CONTACT US
● Sending an email to: firstname.lastname@example.org
● Writing us at:
Veteran Benefit Consulting Group
We will respond to you by email or telephone.
DIGITAL MILLENNIUM COPYRIGHT ACT (“DMCA”) NOTICE
If you believe any material available via this website infringes a copyright you own or control, you may file a notification of such infringement with our Designated Agent as set forth below:
Veteran Benefit Consulting Group
Please see 17 U.S.C. §512(c)(3) for the requirements of a proper notification. Please note that if you knowingly misrepresent in your notification that the material or activity is infringing, you will be liable for any damages, including costs and attorneys’ fees, incurred by us or the alleged infringer as the result of our relying upon such misrepresentation in removing or disabling access to the material or activity claimed to be infringing.
If a notice of copyright infringement has been filed against material posted by you on the website or social media, you may make a counter-notification with our Designated Agent listed above, provided that such counter-notification complies with the requirements of 17 U.S.C. §512(g)(3). If we receive a valid counter-notification, it may reinstate the removed or disabled material in accordance with the DMCA.