Privacy & Cookie Policy

Welcome to Stewart Mountain Lodging, LLC (SML), a software-based and staff-powered property and vacation rental management service (the “Service”).

The Service is owned and operated by SML, a Utah LLC  (collectively, the “Company”, “we”, “us” and “our”) operates the website www.stewartmountainlodging.com the “Site”.

We, at SML, respect your privacy. This privacy policy (the “Policy”) outlines our privacy practices with respect to the Service, including the ways your personal information and data is collected, stored, used and shared.

Providing us with your personal information is a choice you make. We appreciate that and thank you for making this choice. You are not legally obligated to provide us with this information, but we do need it to allow you to use the Service.

This Policy is combined into our Terms of Service (the “Terms”), and is a part of them. Please refer to our Terms of Service for more information about how the Service works.

INFORMATION WE COLLECT

Information you actively provide us –

Registration information. The Service is available only to registered users. When you register, we will ask that you provide basic information such as your name, address, mobile phone number and email address.

Payment information. We also collect your payment information through which we will collect the Service’s applicable fees. You will be asked to provide your payment method and billing information.

Content on the Service. Your use of the Service may involve submission of various types of content, such as correspondence with guests, guests’ contact information, etc. The precise types of content depends on the features of the Service you choose to use.

Inquiries. When you submit an inquiry or customer-service request, you may provide additional personal details depending on the inquiry or request.

INFORMATION WE AUTOMATICALLY COLLECT

Integration data. The Service is particularly aimed for properties listed on and operating through third party platforms such as Airbnb (“Third Party Channels”). After you register, you may interconnect the Service with each of your accounts on Third Party Channels (each interconnection is named an “Integration”). Once you connect to an Integration, the Service imports the property and guest related data in your accounts on the respective Third Party Channel, such as listings, reservations, past guests, etc.

Analytical usage data. We collect analytical information about your use of the Service and your interactions with the Service’s interface, your session durations and the web pages you accessed. This may also include basic information about the device you use to access the Service, including its type, operating system, language settings, the Internet Protocol (IP) address through which your device accessed the Service, and the city or town where the device you used to access the Service is located.

USE OF COLLECTED INFORMATION

• We may use the information we collect for the following purposes:
• Operating the Service and providing its features and functionalities
• Sending you notifications, messages, communications and announcements related to the Service
• Improving and customizing the Service and developing new services
• Providing you with support, handling complaints and contacting you when we believe it is necessary
• Enforcing the Terms and this Policy and preventing misuse of the Service
• Complying with any applicable law and assisting law enforcement agencies and competent authorities, if we believe it is necessary or justified; and
• Taking any action in any case of dispute involving you, with respect or in relation to the Service

SHARING INFORMATION COLLECTED

We may share the information outlined in this Policy, with others, in any of the following instances:

• With contractors and service providers, in order to operate, maintain and enhance the Service, and provide you with the particular features of the Service you requested
• With Third Party Channels, in order to maintain your account on the Service and on Third Party Channel updated
• Messages you address to guests and prospective guests will be sent to them
• If you have breached the Terms, abused your rights to use the Service, or violated any applicable law. Your personally identifiable information may be shared with competent authorities and with any third party, if we believe it is necessary or justified
• If the operation of the Service is organized within a different framework, or through another legal structure or entity (such as due to a merger or acquisition)
• We may share personally identifiable information with our corporate group entities, but their use of such information must comply with the Policy

COOKIES

We and our third-party website analytics provider (such as Google) use cookies on the Service. Cookies are packets of information sent by our servers to your web browser and then sent back by the browser each time it accesses our servers. The cookies may contain a variety of information, such as the web pages you have accessed, session durations and IP addresses. Cookies are used for various purposes, such as to collect statistical information about your use of the Service and save you the need to re-login with your username and password when you use the Service.

This information is used to make websites work more efficiently, as well as to provide business and marketing information, and to gather such personal data as browser type and operating system, referring page, path through site, domain of ISP, etc. for the purposes of understanding how visitors use a website. Cookies and similar technologies help us tailor our website to your personal needs, as well as to detect and prevent security threats and abuse.

If you wish to block cookies, you may do so through your browser’s settings. You can delete cookies that are already on your computer and you can set your browser to prevent them from being placed going forward. Please refer to the browser’s help menu for further information. However, please bear in mind that disabling cookies may adversely affect your user experience on the Service. To learn more about how to reject cookies, visit www.allaboutcookies.org

AGGREGATED INFORMATION

We may use the information we collect, as outlined above, to compile anonymized or aggregated information. We may share, sell or otherwise communicate and make available such anonymized or aggregated information to any other third party, at our sole discretion. However, we will not knowingly or intentionally share information that can be reasonably used to reveal your identity without your consent.

TRANSFER OF DATA OUTSIDE YOUR TERRITORY

We may store and process information in various locations throughout the globe, including through cloud services. The laws in those other countries may provide a lesser degree of data protection than the laws of your own country. You agree to the transfer of your information to such other countries for the purpose of processing as described in this Policy, including through cloud services.

INFORMATION SECURITY

We implement measures to reduce the risks of damage, loss of information and unauthorized access or use of information. These measures do not provide absolute information security. Therefore, it is not guaranteed and you cannot expect that the Service will be immune from information security risks.

DATA RENTENTION

We retain personally identifiable information for as long as we deem necessary for the purposes set forth above. We may delete information from our systems, without notice to you, once we deem it is no longer necessary for the purposes set forth above.

CALIFORNIA RESEIDENTS

The following disclosure is made pursuant to California Online Privacy Protection Act: When you use our Service, other parties, such as Google may collect personally identifiable information about your activities over time and across different websites or online services.

RESIDENTS OF THE EUROPEAN UNION

The following disclosure is made pursuant to the European General Data Protection Regulation (GDPR):

As a data controller of our clients’ personal data, we are committed to protecting and respecting your privacy in compliance with EU- General Data Protection Regulation (GDPR) 2016/679, dated April 27th 2016. This privacy statement explains when and why we collect personal information, how we use it, the conditions under which we may disclose it to others and how we keep it secure. This Privacy Statement applies to the use of our products and to our sales, marketing and customer contract fulfilment activities. You have the right to withdraw your consent at any time; and to submit a complaint to the relevant supervisory data protection authority.

OUR LEGAL BASIS FOR COLLECTING PERSONAL DATA

Collecting personal data based on consents:

The collection of personal data based on consent from the data subject will be done by using “Consent Forms” that will store documentation related to the consent given by the individual. Individual consents will always be stored and documented in our systems.

Collecting personal data based on contracts:

We use personal information for fulfilling our obligations related to contracts and agreements with customers, partners and suppliers.

Collecting personal data based on legitimate interest:

We may use personal data if it is considered to be of legitimate interest, and if the privacy interests of the data subject do not override this interest. Normally, to establish the legal basis for data collection, an assessment has been made during which a mutual interest between SML and the individual person has been identified. This legal basis is primarily related to our sales and marketing purposes. We will always inform individuals about their privacy rights and the purpose for collecting personal data.

When do we collect personal data about you?

• When you are using our products.
• When you interact with us in person, through correspondence, by phone, by social media, or through our websites.
• When we collect personal information from other legitimate sources, such as third-party data aggregators, SML marketing partners, public sources or social networks. We only use this data if you have given your consent to them to share your personal data with others.
• We may collect personal data if it is considered to be of legitimate interest, and if this interest is not overridden by your privacy interests. Before data is collected we make sure an assessment is made, ensuring that there is an established mutual interest between you and SML.

What type of personal data is collected?

We collect your name, phone number, title and email address, in addition to your company’s name and contact information. We may also collect feedback, comments and questions received from you in service-related communication and activities, such as meetings, phone calls, documents, and emails. From our websites, we may collect your IP-address and actions taken on the site.

Why do we collect and use personal data?

We collect and use personal data mainly to perform direct sales, direct marketing and customer service.

We may use your information for the following purposes:

• Send you marketing communications which you have requested. These may include information about our services, events, activities, and promotions.
• Send you information about the services that you have purchased from us.
• Perform direct sales activities in cases where legitimate and mutual interest is established.
• Follow up on incoming requests (customer support, emails, SMS, chats, or phone calls).
• Provide access to our Customer Support portal or the website.
• Perform contractual obligations such as order confirmation, license details, invoice, reminders, and the like. The contract may be with SML directly or with a SML partner.
• Notify you about any disruptions to our services (system messages).
• Contact you to conduct surveys about your opinion on our products and services.

HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We store personal data for as long as we find it necessary to fulfill the purpose for which the personal data was collected, while also considering our need to answer your queries or resolve possible problems, to comply with legal requirements under applicable laws, to attend to any legal claims/complaints, and for safeguarding purposes.

This means that we may retain your personal data for a reasonable period of time after your last interaction with us. When the personal data that we have collected is no longer required, we will delete it in a secure manner. We may process data for statistical purposes, but in such cases, data will be anonymized.

YOUR RIGHTS TO YOUR PERSONAL DATA

     You have the following rights with respect to your personal data:

• The right to request a copy of your personal data that SML holds about you.
• The right to request that SML correct your personal data if inaccurate or out of date.
• If you are a customer you may update your user profile by logging onto SML Platform and selecting “Account” and then “My Profile”.
• The right to request that your personal data be deleted when it is no longer necessary for SML to retain such data.
• The right to withdraw any consent to personal data processing at any time. For example, your consent to receive e-marketing communications:
• If you want to withdraw your consent to e-marketing, please make use of the link to manage your subscriptions included in our communication. Please note that you may still receive system messages and administrative communications from SML, such as order confirmations, system messages and notifications about your account activities.
• The right to request that SML provide you with your personal data and, if possible, to pass on this information directly (in a portable format) to another data controller when the processing is based on consent or contract.
• The right to request a restriction on further data processing, in case there is a dispute in relation to the accuracy or processing of your personal data.
• The right to object to the processing of personal data, in case data processing has been based on legitimate interest and/or direct marketing.

Changes to this Privacy Policy

We may change this Policy. We will provide you notice of such changes through the Service’s interface. Your continued use of the Service constitutes your consent to the amended Policy. If you do not consent to the amended Policy, we may terminate the Terms and your account on the Service and block your access to, and use of, the Service, upon the elapse of 30 days after you decline to accept the revised Policy.

In case of legal requirement or necessity, we may also introduce immediate changes to this Policy. The latest version of the Terms and its effective date will always be accessible on the Service.

Contact Us

You may contact us with any questions, requests and complaints, at: info@stewartmountainlodging.com or call us at 801-701-6208.

Effective date of the policy: May 24, 2018