LAST MODIFIED: FEBRUARY 1, 2019

INTRODUCTION:

This Privacy Policy (this “Policy”) describes (a) the types of information that 3Sixty (“3Sixty”, “we,” “our,” or “us”) may collect from you (“you”), that you may provide us when you use the website www.stay3sixty.com (the “Website”) or that is provided to us by third-parties, and (b) our practices for collecting, using, maintaining, protecting, and disclosing that information.

We are made up of different legal entities with details that can be found at https://staywithreside.com/resideworldwideentities. These entities make up our “Company Group” and when we refer to “3Sixty”, “we”, “us” or “our” in this Policy, we are referring to the relevant Company Group processing your Personal Information. It is important to us that your Personal Information is protected, private and secure, so 3Sixty shall serve as the controller that is responsible for your Personal Information.

We have appointed a data protection officer who is responsible for answering questions in connection with this Policy. If you have any questions regarding this Policy, your Personal Information, or the exercise of your legal rights, contact the data privacy officer at the details set out below. 

Contact Details:  

Contact Name: Jenny Anderson Email: jenny.anderson@staywithreside.com Address: 6525 240th Street SE, Woodinville, WA 98072 Phone: (425) 375.2761

Please read this notice carefully to understand our policies and practices for processing and storing your personal data.  By accessing or using the Website, including purchasing or obtaining our products or services through the Website, you agree to this Policy. If you do not agree with the terms of this Policy, do not use the Website or provide any information to us.

This Privacy Policy may change from time to time (see Changes to Our Privacy Policy), so please check periodically for updates.  This Policy was last updated on February 1, 2019. This Policy may change from time to time. If there is a material change to this Policy, we will notify you in an appropriate way (for example, by email or pop-up notice when you visit the Website.

 1. Information We Collect. 

• “Personal Information”

  means information that identifies you or another person as an individual such as your name, mailing address, email address, telephone number, IP address, location or any other identifier by which you or any other individual may be contacted online or offline.

• “Non-Personal Information”

  means information that does not identify you as an individual, such as your browser type, your internet connection, the URL of the previous website you visited, the equipment you use to access the Website, and details about how you use the Website.

1. The following are categories of Personal information that we may collect (a) when you provide it to us; (b) automatically through the Website; or (c) through third-parties:

   • “Account Info”: information provided by you when you setup an account with us such as your name, email, birth date, gender, postal code, and country.

   • “Usage Info”: information about how you use the Website and any of our products or services.

   • “Technical Data”: information about your technology such as your IP address, browser type and version, time zone settings and location, browser plug in types and versions, operating system and platform, and other devices you use to access the Website.

   • “Marketing Data”: information regarding our communication with you about marketing such as communication preferences, whether you want to receive marketing information from us or third parties, and what categories of marketing information you wish to receive.

   • “Payment Data”: information provided when you make purchases through the Website such as your name, date of birth, credit or debit card number, expiration date, bank account, postal code, phone number, and details of your transaction history.

   • “Voluntary Data”: information that you provide to us about your interests, your responses to surveys, feedback about the products, services, or the Website.

2.  We use aggregated information that includes age, gender and location for any purpose. Aggregated data may be derived from your Personal Information, but is not considered Personal Information and this data does not directly or indirectly reveal your identity. 

 We do not collect any “Special Categories” of Personal Information about you (such as race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, information about your health, and genetic and biometric data.)

2. How We Collect Your Information.

We may collect information (a) when you provide it to us; (b) automatically through the Website; and (c) through third-parties.  This Privacy Policy does not apply to any data collected by us other than personal data collected through the Website.

a.  Information You Provide to Us.  When you use the Website, you may choose to provide us with both Personal and Non-Personal Information, including when you:

·      Visit the Website.

·      Purchase or obtain our products or services.

·      Complete and submit forms on the Website.

·      Contact us.

·      Enter into a contest or promotion sponsored by us.

·      Submit a product review.

·      Report a problem with the Website or our products.

 b.      Information We Collect Automatically. 

As you use and interact with the Website, we may automatically collect Technical, Usage and/or Marketing Data such as details regarding your access to and use of the Website, log files, product purchase history, browser type, operating system, and device information. If you do not want us to collect this information you may contact us at the contact information in the Introduction. You should understand that my opting-out of the collection of certain Personal Information may prevent us from providing certain products or services to you, and could affect your ability to use all of the features of the Website.

• Tracking Technologies. The technologies we use for automatic information collection may include “cookies.” A cookie is a small file placed on your browsing device. It may be possible to refuse to accept cookies by activating the appropriate setting on your computer, tablet, or smartphone. However, if you select this setting you may be unable to access certain parts of our Website.

• Third-Party Use of Cookies and Other Tracking Technologies. Some content on the Website, including certain Website capabilities such as payment processing, may be served or performed by third-parties. These third parties may use cookies or other tracking technologies to collect information about you when you use the Website or purchase or acquire our products or services. We do not control these third parties' tracking technologies or how they may be used. If you have any questions, for example, about an advertisement or other targeted content, or about the security of our online payment processing, you should contact the responsible provider directly.

• Do Not Track. Do Not Track is a privacy preference that you can set in your web browser. When you turn on the Do Not Track signal, your browser sends a message to websites requesting them not to track you. For information about Do Not Track, visit www.allaboutdnt.org. At this time, we do not respond to Do Not Track browser settings or signals. In addition, we may use other technology that is standard on the internet, such as pixel tags, web beacons, and other similar technologies, to track visitors to the Website. Those tools may be used by us and by third parties to collect information about you and your internet activity, even if you have turned on the Do Not Track signal.

 c.      Information We Collect from Third Parties. We may receive Personal Information about you from various third parties as set out below:

·      Suppliers of alternative accommodation

·      Relocation, Business, Employer or other Clients

·      Online Travel Agencies (“OTAs”)

·      Advertising networks

·      Business Partners

·      Social Media applications

·      Search information providers

·      Data brokers / aggregators

·      Publicly Available Sources

3. Why We Collect Your Personal Information.   

We may use your Personal Information for the following purposes:

●       Specific reason. If you provide data for a certain reason, we may use your data in connection with the reason for which it was provided or the reason that was stated when it was collected. For instance, if you contact us by e-mail, we will use the data you provide to answer your question or resolve your problem and will respond to the email address from which the contact came.

 ●       Access and use. If you provide data in order to obtain access to or use of the services or any functionality thereof, we will use your data to provide you with access to or use of the services or functionality, enable your participation in the services and features, notify you about changes to our services, and to monitor your use of such services or functionality.

 ●       Internal business purposes. We may use your data for internal business purposes including to help us deliver the services,  improve the content and functionality of the services, to better understand our users, to protect against, identify or address wrongdoing, to enforce our Terms of service or other agreements, to comply with applicable laws, to protect the services and business operations, to manage your account and provide you with customer service, and to generally manage the services and our business.

 ●       Marketing. We may use your data to contact you in the future for our marketing and advertising purposes, including to inform you about services or products we believe might be of interest to you, and to develop promotional or marketing materials and provide those materials to you, and to display content and advertising on the Website that we believe might be relevant to you.

 ●       Permission.  Where not otherwise explained in this Privacy Policy, we may disclose your data with your permission.

We use Personal Information for a number of legitimate interests, including to provide and improve our products and services, administer our relationship with you and our business, for marketing and in order to exercise our rights and responsibilities. More detailed information about these legitimate interests is set out below.

4. Disclosure of Your Information.

We disclose your Personal Information to the following categories of recipients:

• Service Providers

  : to contractors, service providers, suppliers, OTAs, data processors, and other third-parties we use to support our business. These parties are bound by contractual obligations to keep your Personal Information confidential and use it only for the purposes for which we disclose it to them.

• Marketing/Preferred Alliance Partners

  : to tailor your content or to help us understand your use of the Website in order to provide you with better service, and in order to send you promotional communication about the Website.

• Business Partners or Affiliates

  : other companies in the Company Group including affiliates, subsidiaries, advisors, partners and consultants who are bound by confidentiality obligations and security measures.

• Business Transfers

  : to a buyer or successor in the event of a merger, reorganization, dissolution, or other sale or transfer of some or all of our business or assets.

• Law Enforcement:

  to third-parties such as law enforcement, government entities, courts, or other third parties as required or allowed by applicable law when requested. To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

• Controller Interest

  : If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of 3Sixty, its affiliates, customers, users or others such as fraud agencies.

• Business Enterprise:

  If you decide to link your personal information or any of your accounts to the information or account of your company or other organization (each a “Business Enterprise”), such as by adding your work email address, or having a booking facilitated by another party on your behalf, that Business Enterprise will have access to information which can include, but may not be limited to, your name, contact details, permissions and roles, booking information and other information related to your business travel. In addition, in such event, and/or in the event that you are included on a booking designated as being for business purposes by your employer, we may disclose information related to the booking to the Business Enterprise as necessary for the proper performance of any agreement we may have with such Business Enterprise. This also can include, but may not be limited to your booking information, such as your name, dates of travel, number of guests, pricing, accommodation address, and other related information. At the request of you or your Business Enterprise, we may also disclose this information to support services providers engaged by the Business Enterprise.

• Dispute/Emergency:

  In the event of a dispute or an emergency involving a booking, we may also share additional relevant information as needed to safely and quickly address and/or remedy the situation.

5.      International Transfers.

We are located outside of the European Economic Area (EEA).  As a result, when you provide Personal Information to us, that Personal Information is transferred outside of the EEA in order for us to be able to receive and access it.  We will only do this with your consent.

We use external third parties that are based outside the EEA that process your Personal Information in order to carry out activities specified in this Policy. This includes third parties in the following countries: the United States. Whenever we transfer your Personal Information to one of these third parties, we ensure that at least one of the following safeguards are implemented:

• We will only transfer your Personal Information to countries that have been deemed to provide an adequate level of protection for Personal Information by the European Commission.

• Where we use certain service providers, we may use specific contracts approved by the European Commission which give Personal Information the same protection it has in Europe.

• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to Personal Information shared between the Europe and the US.

• Please contact us at our Data Privacy Officer or 3Sixty if you want further information on the specific mechanism used by us when transferring your Personal Information out of the EEA.

6.      Cookie Policy

Application.

This Cookie Policy sets forth our policy with respect to information, including Personal Information, that is collected from Website users through cookies, pixel tags, local shared objects, web storage and other similar technologies.

Cookies and tracking technologies.

A cookie is a piece of information that is placed on your web browser when you access and/or use the Website that stores text and which can later be read back by the services or third parties. Cookies are used to recognize your browser and you as a unique Website user. Cookies may be session cookies (i.e., last only for one browser session) or persistent cookies (i.e., continue on your browser until they are affirmatively deleted). You can manage cookies through your web browser's option settings and through those settings you may be able (a) to receive notifications when you are receiving new cookies; (b) to disable cookies; or (c) to delete cookies. Please refer to your web browser's help section for information on how to do this.

Pixel tags (also known as clear GIFs or web beacons).

A pixel tag is a tiny invisible tag or graphic placed on certain parts of the services or other websites, in emails or in certain other downloadable content, but not on your computer, mobile device or browser, except to the extent that you download the content that contains such tags. Pixel tags do not store data on your computer, mobile device or browser (although they are occasionally downloaded to your computer if contained in an email or other downloadable content) so cannot be managed by you except by deleting the content in which the tag is contained.

Local shared objects (also known as flash cookies).

A local shared object is similar to a cookie, except it is stored on your computer or mobile device, instead of your browser, and it can store more than just text. Local shared objects are stored on your computer or mobile device.

Essential use of these technologies.

We use these technologies and allow third parties to use these technologies in a way that is essential for the operation of our services or parts of our services. For example, we may use cookies to determine where to route your traffic to effectively distribute the Site workload across numerous servers.

We use these technologies and allow third parties to monitor our services and to analyze how you use our services. For example, we may place cookies that allow us (a) to measure the time of your requests to our servers and our responses; (b) to A/B test new features; (c) to record statistics about site usage; (d) to track your activities on the Website; and (e) to track the places from which you come to the services. We may also use third-party cookies to collect information about visitor behavior on our Website for these performance/analytics purposes.

Functional use of these technologies

We use these technologies and allow third parties to use these technologies to allow us to provide certain functionality on the Website and to remember your preferences.

7. Your Choices and Opting Out.

We may periodically send you email messages describing news, information, updates, or promotional offers related to the Website or our products and services.

 You can “opt-out” of receiving emails from us at any time by following the instructions included in your email or by sending a reply stating your request, and we will make the requested changes. Whether you opt-out of receiving promotional emails or not, we reserve the right to email or otherwise contact you with respect to important information, notices or changes relating to our products and services.

 We currently do not participate in any "Do Not Track" frameworks that would allow us to respond to signals or other mechanisms from you regarding the collection of your data.

8.      Data Retention.

We will only retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements. 

9.      Your Legal Rights.

  You have certain legal rights under applicable data protection laws including the following:

• Right to Access:

  You can request a copy and review the Personal Information we process about you.

• Right to Rectification:

  You can request to amend or update your Personal Information that is inaccurate or incomplete.

• Right to Erasure:

  You can request that we delete your Personal Information where there is no good reason to continue processing it or if it was collected unlawfully. We may not always be able to comply with your erasure request for specific legal reasons, which will be notified to you.

• Right to Restrict:

  You can request that we temporarily or permanently stop processing all or some of your Personal Information if: (a) you want us to establish the accuracy of the Personal Information; (b) where the use is unlawful but you do not want it erased; (c) where you need us to hold it for legal purposes; or (d) you have objected to the use of your Personal Information but we need to verify if we have overriding legitimate reasons for processing the Personal Information.

• Right to Object:

  You can object to us processing your Personal Information on grounds relating to your particular situation. You have the right to object to your Personal Information being processed for direct marketing purposes.

• Right to Data Transfer:

  You can request a copy of and transfer your Personal Information in electronic format to you or a third-party. This right only applies to automated information that you consented to us processing or where we used the Personal Information to perform a contract with you.

• Right Not to Be Subject to Automated Decision Making:

  You have the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.

• Withdraw Consent:

  You have the right to withdraw your consent for us to process your Personal Information. (This does not affect the lawfulness of processing your Personal Information prior to the withdrawal of your consent.)

 You may contact our Data Privacy Officer at jenny.anderson@staywithreside.com or Walter Dembiec, Jr., EVP & General Counsel, 3Sixty at jr@staywithreside.com to exercise any of your legal rights. If you are ever not satisfied with our response or believe that your Personal Information is being processed unlawfully, you may contact or lodge a complaint with the competent supervisory authority or seek other remedies under applicable law.

10.      Data Security.

We may store your data itself or such information may be included in databases owned and maintained by our affiliates, agents or service providers. We take what we believe to be reasonable physical, electronic and administrative steps to protect your data from loss, misuse, unauthorized access, inadvertent disclosure, alteration, and destruction. However, no Internet or e-mail transmission is ever fully secure. Although we do our best to protect your data, we cannot guarantee the security of your data transmitted to or on our Website. Any transmission of data is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on the Website.

11.   Children Under the Age of 13.

We do not knowingly collect Personal Information from children under the age of 13. If you are under the age of 13, you should not make a purchase, register, or submit Personal Information to us. If we learn that we have collected or received Personal Information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any Personal Information from or about a child under 13, please contact us at Data Privacy Officer at jenny.anderson@staywithreside.com or Walter Dembiec, Jr., EVP & General Counsel, 3Sixty at jr@staywithreside.com.

12.   Changes to Our Privacy Policy.

We may modify or amend this Policy from time to time.  The date this Policy was last revised is identified at the top of the page, and the terms of this Policy are effective as of that date.

13.   Contact Information.

To ask questions or comment about this Policy and our privacy practices, contact us at Data Privacy Officer at jenny.anderson@staywithreside.com or Walter Dembiec, Jr., EVP & General Counsel, 3Sixty at jr@staywithreside.com.

California Consumer Privacy Act

This provision applies solely to all visitors, users, and others who 3Sixty in the State of California. We adopt this notice to supplement our Privacy Policy and comply with the California Consumer Privacy Act of 2018 (“CCPA").

Information We Collect

We collect information that identifies, relates to, describes, references is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("personal information").  In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

We obtain the categories of personal information listed above from the following categories of sources as described above (see How We Collect Personal Data).

Use of Personal Information

We may use, or disclose the personal information we collect for one or more of the purposes described above (see How We Use Personal Data).  We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We do not sell personal information.

We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Company has disclosed personal information for a business purpose to the categories of third parties indicated in the chart below.

Your Rights and Choices

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the "right to know").  You also have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the "right to delete"). Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies.  We will delete or deidentify personal information not subject to an exception under the CCPA and will direct our service providers to take similar action.

To exercise your rights to know or delete, please submit a request by either:

• Emailing us at jenny.anderson@staywithreside.com

• Visiting us at www.stay3sixty.com

You may only submit a request to know twice within a 12-month period. Your request to know or delete must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.  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.  You do not need to create an account with us to submit a request to know or delete.  We will only use personal information provided in the request to verify the requestor's identity or authority to make it.

Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please email at jenny.anderson@staywithreside.com

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

We will not discriminate against you for exercising any of your CCPA rights.