PRIVACY NOTICE
Effective as of May 30, 2024
Privacy Statement
Inhabit IQ and its family of software brands take pride in conducting business responsibly and ethically. We place the highest regard on the data privacy and security of our customers and on our legal obligations to protect such personal data.
Virtual Resort Manager (“VRM,” “we,” “us” or “our”), as one of the Inhabit IQ brands, developed a data privacy program that respects and protects the privacy rights of individuals whose personal information we process. We recognize that data privacy coincides with data protection, thus, we implement reasonable and appropriate data security and protection measures to preserve the confidentiality, integrity, and availability of the personal information we process.
I. Who are we?
Virtual Resort Manager (“VRM,” “we,” “us” or “our”) is a hospitality marketing company operating under Inhabit IQ, a global PropTech software company serving the residential and vacation property management industries offering software-as-a-service (SaaS) solutions for core areas like accounting and operations, customer relations management, marketing, background screening, rent payment processing, and insurance.
We provide a complete all-in-one virtual vacation rental management software with all the capabilities vacation property management companies and vacation rental owners need to manage their properties through fully integrated vacation rental management solutions, accounting, digital marketing tactics and solutions such as Search Engine Optimization (SEO), web design services, paid search management, social media and email marketing, and advanced reporting, among others. When we use the term "Service(s)", we mean collectively:
1. The information provided through websites owned and controlled by us, including the website at https://www.virtualresortmanager.com/ and any related apps (the “Site(s)”);
2. The provision of online tools for real estate and property management and related services to those who purchase such tools and services; and
3. VRM marketing and business development activities, including any social media campaigns we create, and emails that we send (“Marketing”).
We offer these Services to property management companies and owners (“Customers”). The Services are intended for a general audience and are not targeted to children under the age of 13.
We are a “Data Controller” under Data Privacy Laws when we process personal information relating to our Customers or potential Customers, their representatives or employees, our suppliers, and vendors.
We are a “Data Processor” under Data Privacy Laws when we process personal information on behalf of our Customers and relating to our Customer’s Guests or Visitors in the performance of our Services. When we process personal information in this capacity it will be set out in a written contract with our Customers, the Data Controller, and such Data Controller’s Privacy Notice would apply as opposed to this Privacy Notice.
II. What is the scope of this Privacy Notice?
We strive to be transparent and keep you informed on how we process your personal information through this notice. This notice sets out how we collect, use, store, share, dispose, and protect your personal information as a Data Controller and a Data Processor.
This Privacy Notice covers the disclosures that are required by “Data Privacy Laws” governing our processing of personal and sensitive personal information, which include, but are not limited to the following:
| Law | Scope | Effectivity |
| “GDPR”
General Data Protection Regulation | Imposes obligations onto organizations anywhere, so long as they target or collect data related to people in the EU. | May 25, 2018 |
| “PIPEDA” Personal Information Protection and Electronic Documents Act | Applies to private sector organizations engaged in commercial activity or operating in Canada. | January 1, 2001 |
| “CCPA” The California Consumer Privacy Act | California state law that addresses the privacy rights of California consumers. It was updated, amended and expanded by California Privacy Rights Act (CPRA). In this Privacy Policy, CCPA means CCPA as amended by CPRA. | CCPA: January 1, 2020 CPRA: January 1, 2023 |
| “CPA” Colorado Privacy Act of 2021. | Applies to legal entities conducting business in Colorado or delivering products or services targeted to Colorado residents | July 1, 2023 |
| “CTDPA” Connecticut Data Privacy Act of 2022 | The act applies to those who conduct business in the state or who produce products or services targeted to Connecticut residents. | July 1, 2023 |
| “FDBR” Florida Digital Bill of Rights | Applies to for-profit entities that conduct business in Florida and collect personal data about Florida consumers (or are the entity on behalf of which such information is collected). | July 1, 2024 |
| “MCDPA” Montana Consumer Data Privacy Act | Companies that conduct business in Montana or persons that produce products or services that are targeted to residents of Montana | October 1, 2024 |
| “OCPA” Oregon Consumer Privacy Act | Applies to any person that conducts business in Oregon or provides products / services to Oregon residents | July 1, 2024 |
| “TDPSA” Texas Data Privacy and Security Act | Applies to for-profit businesses or persons that does business in Texas or produces a product or service consumed by a Texas resident. | July 1, 2024 |
| “UCDPA” Utah Consumer Privacy Act of 2022 | The Act regulates company that conducts business in Utah or produces a product or service that is targeted to consumers in Utah. | December 31, 2023 |
| “VCPDA” The Virginia Consumer Data Protection Act of 2021 | Provides Virginia consumers with specific rights regarding their personal information that took effect on | January 1, 2023. |
This notice applies as we process personal information as a Data Controller relating to:
- visitors to our VRM Site(s);
our Customers including their representatives, officers, employees, partners, independent contractors, agents and other authorized Users; and
our prospective Customers, including their representatives, officers, employees.
This Privacy Notice does not cover the practices of companies we do not own or control or people we do not manage and this Privacy Notice does not apply to any third-party sites that may link to or be accessible from our Sites.
We use some phrases in this Privacy Notice that are unique to our business or our Services. Below are definitions of some of the key terms.
● "Personal Information or Personal Data" refers to information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information does not include certain de-identified or aggregated information, information publicly available in government records, or certain other information excluded from the scope of various Data Protection Laws.
● “Sensitive Personal Information” is a type of personal information depending on what is considered as sensitive personal information as provided under the applicable Data Privacy Laws, sensitive personal information is that which reveals the following:
o Personal identification numbers, including social security, driver's license, passport, or state ID card numbers
o Account or debit or credit card numbers combined with passwords or codes that would enable access to the accounts
o A consumer's precise geolocation
o A consumer's racial or ethnic origin, religious beliefs, or union membership, individual’s medical history, mental or physical health condition or medical treatment or diagnosis, sex life or sexual orientation, or citizenship or citizenship or immigration status
o A consumer's mail, email, or text message content unless the information was intentionally sent to the business
o A consumer's genetic data, biometric data that may be processed for the purpose of uniquely identifying an individual
o Personal data from a known child under 13 years old (for those consumers in CO, CT, VA).
o This also includes Special Categories of Data as defined under the GDPR: personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.
● “Processing” means any operations performed on a personal information, including: collecting, storing, retrieving, consulting, analyzing, disclosing or sharing with someone else, erasing, or destroying personal data.
● “Customer” refers to the property management companies or owners of vacation rental properties who we contract with and provide our Service for.
● “Guest” refers to the individuals who avail the service of our Customers whose personal information we may handle on behalf of or upon the instructions of our Customers as part of or as needed by the Services we provide.
● “User” refers to individuals who are given access to the platforms we offer our Customers. They can be Primary Users: representative, staff, vendor, employee or personnel of our Customers or Secondary Users: the Guests who booked and have actual reservations with our Customers or Visitors of our Customer’s website.
III. What do we collect?
- Directly from you when you interact with our customer support by
email, regular mail or telephone; or when you use any of our application
or solutions as authorized User or representative of our Customer:
● Name, phone numbers, email address or unique personal identifiers (wireless device ID, cookies, IP address) (“Identifiers”).
● Occupation, position or designation (“Demographic Data”).
● Company name, company country and state, commercial information (such as transaction data, purchase history, or delivery information) (“Commercial Data”);
● Internet or other network or device activity (such as browsing history, browser type and language, operating system or app usage) (“Internet Data”).
● Usernames, passwords, log-in credentials (“Log-in Data”) - Directly from you as a visitor to one of our Site:
When you visit our Site, you may choose to provide information to us, such as when you contact us to request or provide information through our “Get in Touch” or “Support” page on the Site.
In addition, when you interact with our Site, we use technology and Google tools (such as Google Analytics, Google AdSense, Google Display Network Impression Reporting) to gather information on how visitors are using the Site and Services.
We collect IP address information so that we can properly manage our system and gather information about how our site is being used. This includes the device type and browser you are using, location data, the pages you are viewing and your interactions on the page. Your IP address may be associated with records containing Personal Information. We collect details of visits to our Site, including the volume of traffic received, logs and the resources that you have accessed. We may also collect certain location information such as your mobile device’s GPS signal, or information about nearby WiFi access points and cell towers.
We may collect the following categories of information from our Site:
● Name, company name, phone number, email address, state or province, unique personal identifiers (cookies, IP address), (“Identifiers”).
● Internet or other network or device activity (such as type of device, internet connection, browser type and version, time zone, operating system and platform, referring/exit pages, account access date/time stamp, UTMs (Urchin tracking modules) for lead source) (“Internet Data”). From our Customer as needed for us to perform our Services for them.
● Name, phone number, email address, postal address, information about your real estate assets, and any other information necessary to complete applicable documents or applications provided (“Identifiers”).
B. Data from Guests or Visitors
- Directly from you as a Guest or our Customer website’s Visitor who has opted to receive marketing communicates and product updates and offers from our Customer.
● Name, phone number, email address, postal address, state identification card numbers, social security number, driver's license number or unique personal identifiers, passport number, insurance policy number, bank account number, wireless device ID, cookies, IP address (“Identifiers”).
● Employment details, citizenship, marital status, military or veteran status, monthly income and size, gender and birthdate (“Demographic Data”).
● Financial information (such as credit or debit card information, verification number, and expiration date) (“Financial Data”).
● Usernames, passwords, log-in credentials (“Log-in Data”)
● Internet or other network or device activity (such as browser type and language, operating system or app usage) (“Internet Data”). From our Customer and from our service providers and business partners as needed for us to perform our Services.
● Name, phone number, email address, postal address, state identification card numbers, social security number, driver’s license number or unique personal identifiers, passport number, insurance policy number, bank account number (wireless device ID, cookies, IP address), (“Identifiers”).
● Employment details, citizenship, marital status, military or veteran status, monthly income and size, gender and birthdate (“Demographic Data”).
IV. How we use the personal information we collect
We only collect the information reasonably necessary to provide our Services, to carry out our operations which may involve automatic processing using machine learning and artificial intelligence applications, as required by law, and for the other legitimate business purposes, under applicable laws.
Some of these uses may, under certain circumstances be based on your consent, may be necessary to fulfill our contractual commitments to you or our Customers, or are necessary to serve our legitimate interests as provided below:
● To facilitate the use of the software application, to maintain and administer our Customer’s account which includes sending transaction records, notice and other documents necessary for the continued use of the application and for other purposes that would be necessary or beneficial to administer our Customer’s use of the same (“Servicing”).
● To continuously provide you or our Customers with our services through your use of the platform and access of its database (“Servicing”).
● To respond to your queries, comments, feedback, or requests and address your complaints and provide customer support (“Servicing”).
● To verify or ascertain your identity, uniquely identify you or your business and identify potentially fraudulent activity (“Fraud Prevention”).
● To carry out our obligations arising from of our contracts with our Customers (“Servicing”).
● To conduct research and gain an understanding of the users of our platform, their experiences and preferences to further improve the platform (“Quality Improvement”).
● To assist in business development, compile statistics regarding how the Site or our Service is used in order to improve our them, for example, we may use your personal data to improve the layout of our Site based on the click path you utilized to access certain information within the Site (“Quality Improvement”).
● To run system diagnostics to ensure that platform is functioning properly and to improve the user experience (“Quality Improvement”).
● To build and improve the accuracy of our automated methods of processing (including artificial intelligence or AI, such as Chat Bots you may use as part of our Services), where we manually review some of the predictions and interferences produced by the automated methods against the underlying data from which the predictions and inferences were made. For instances, with your permission and for the purpose of improving our Chat Bot technologies, we manually review short snippets of text or voice data that we have taken steps to de-identify. This manual review may be conducted by our employees or vendors who are working on our behalf. We do not use your personal information for training artificial intelligence. ("Quality Improvement").
● To detect or prevent security incidents or other illegal activity, debug, verify or maintain quality or safety or improve or upgrade a service or device owned or controlled by us (“Security”)B. For our own marketing and advertising activities ("Marketing"):
● To communicate with our Customers and Potential Customers regarding services, activities, programs, trainings, promotions, services, products or other offers in which they have indicated an interest or to which they’ve subscribed and to contact them with information that may be of interest to them.
● To provide our Customers and Potential Customers newsletters, articles, alerts and announcements and other information we think they may find useful or which they have requested from us.
● To personalize our Customers and Potential Customers’ experience and allow us to deliver individualized content and product offerings according to their specific interests.
● To provide our Customers and Potential Customers with the marketing materials of third parties which we think may interest you.
C. For compliance with our legal obligations, regulatory requirements and for other legal purposes ("Legal"):
● To process any complaints, implement preventive measures and to investigate act, omission, or misconduct that would constitute a violation of our contracts and of the applicable laws.
● To verify your identity or conduct internal audits or reviews.
● To enforce our Terms and Conditions, and other agreements.
● To gather the necessary information required by law, record keeping and good business practices.
● To comply with our legal obligations and other regulatory requirements.
● To protect our lawful rights and interests in court proceedings and to establish, exercise or as defense from legal claims.
We do not monitor or statistically profile visitors to our Site or collect, in any automated manner, any special categories or sensitive Personal Information about you. No automated decision-making, including statistical profiling, is used when processing your Personal Information.
Chat and Artificial Intelligence
Chat and artificial intelligence features connect you with information and intelligently sense, process, and act on information, learning and adapting over time.
A note about accuracy: Our chat and artificial intelligence features generate responses by reading a user’s request and, in response, predicting the words most likely to respond to such request. In some cases, the responses may not be the most factually accurate. For this reason, you should not rely on the factual accuracy of output from these features. If you notice that these features provide factually inaccurate information and you would like us to correct the inaccuracy, you may submit a correction request via email to [email protected]. Given the technical complexity of how these features work, we may not be able to correct the inaccuracy in every instance.
What Information Do Our Websites Collect for Interest-Based Advertising?
We and our third-party advertising partners may use cookies or web beacons to collect information for the purposes of interest-based advertising based on your visits to our Site. These cookies identify the pages you view, the links and ads you click on, other actions you take on those websites, and the referring website. Similarly, online advertisers use cookies to deliver advertising to you for companies other than us based on your visits to our Site and other websites.
V. How we share and disclose your personal information
The below chart summarizes the categories of personal and sensitive personal information we collect, from where we collect it, how we use it, and with whom we share it.
This chart is updated in an annual review and reflects the prior twelve (12) months from the date of last review in compliance with the CCPA.
We have not sold any personal information to third parties for commercial purposes or monetary value however we do disclose personal information for internal business purposes or operational purposes of our business (servicing, quality improvement, fraud detection, security, legal).
| CATEGORIES OF DATA COLLECTED | EXAMPLE DATA ELEMENTS | SOURCES WE COLLECT FROM | PURPOSES BEHIND COLLECTION, USE, AND SHARING | CATEGORIES OF THIRD PARTIES WE DISCLOSE TO | |
| Identifiers | Name, phone number, email address, unique personal identifiers (wireless device ID, cookies, IP address) Gender, martial status, occupation | From our Customers From Guests / Visitors | Servicing, Marketing
| Our Service Providers | |
| Identifiers | Name, phone number, email address, unique personal identifiers (wireless device ID, cookies, IP address) | From our Customers, Guests
| Quality Improvement Fraud Prevention Legal
| Corporate Subsidiaries and Affiliates | |
| Financial Data | Financial information such as credit or debit card information, verification number, and expiration date | From Guests | Servicing | Our Service Providers | |
- Third-party Service Providers: Your Personal Information will only be shared with and processed by our affiliates and non-affiliated third-party service providers as permitted by law and for the purposes described in this Privacy Notice. We may disclose Personal Information to certain non-affiliated specialized service providers, including professional advisors, consultants, technical service providers, and other third parties, who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them. We may disclose your Personal Information to third-party service providers to provide us with services such as Site hosting, including information technology and telephony services, and related infrastructure, customer service, e-mail delivery, auditing, and other similar services.
- Corporate Subsidiaries and Affiliates: We share the collected personal information as described in this notice with our subsidiaries and affiliated businesses within the Inhabit IQ, each of which use your personal information consistent with this Privacy Notice. Those businesses may also use your personal information for each of their own purposes, including marketing purposes. Please visit their Privacy Notice on their website to learn more.
- Business Partners: Where permitted by law, with our third-party business partners, such as companies offering products or services of interest to you, advertising partners and other third parties for those third parties’ own commercial or marketing purposes, such as to serve targeted advertisements.
- Business Transfers: When applicable, we may share your information in connection with a substantial corporate transaction, such as the sale of a Site, a merger, consolidation, asset sale, or in the unlikely event of bankruptcy.
- With Your Consent or at Your Direction: We may share information for any other purposes disclosed to you at the time we collect the information or pursuant to your consent or direction.
- Other Legal Reasons: In addition, we may use or disclose your Personal Information as we deem necessary or appropriate: (1) under applicable law; (2) to respond to requests from public and government authorities including public and government authorities; (3) to pursue available remedies or limit damages we may sustain; (5) to protect our operations or those of any of our affiliates; (6) to protect our rights, privacy, safety or property of, our affiliates, you and others; and (7) to enforce our terms and conditions.
When the information collected from or about you is not defined as personal information under applicable law, we may share such non-personal, de-identified information or aggregated information with third parties at our discretion.
VI. How long we retain personal information
We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Notice and in order to provide you the Services, and for as long as your account is active or as needed to provide you Services. We will also retain your information to comply with our legal obligations, to conduct audits, resolve disputes, and enforce of our agreements.
VII. How we secure your personal information
We use reasonable organizational, technical and physical measures to maintain the privacy and security of your Personal Information within our organization against any unauthorized access, use, disclosure, loss or alteration, or theft of personal information. We maintain policies and practices to ensure the protection of your personal information. Depending on the volume and sensitivity of the information, the purposes for which it is used and the format in which it is stored, we implement a combination of measures to protect your personal information, including:
● Internal policies and procedures that define the roles and responsibilities of our employees throughout the information life cycle and limits their access to such information on a “need-to-know” basis;
● Technical safeguards such as encryption, firewalls, antivirus software and similar measures to protect information stored in electronic format;
● A designated Privacy Officer to monitor our compliance with applicable privacy laws;
● Employee privacy and data security training; and
● Procedures for receiving, investigating and responding to security incidents involving personal information.
Unfortunately, no data transmission or storage system can be guaranteed to be secure at all times. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.
If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Us” section below. We will let you know promptly if a breach occurs that may have compromised the privacy or security of your information.
VIII. Your Choices and Rights
We offer you certain choices and you also may have certain rights in connection with the personal information we collect about you.
A. Your Choices
To ask us to remove your information from our marketing mailing lists, please contact us as outlined in the How to Exercise Your Rights Section below.B. Your Rights
Subject to applicable Data Privacy Law, you may have certain rights to know, access, update, port your personal data, correct inaccuracies, delete, restrict processing of your personal information in our custody and control.
For security purposes, we will verify your identity when you request to exercise your data privacy rights. For certain types of requests, we may also need to ask you for additional information to verify your identity. Once we have verified your identity (and your agent, as applicable), we will respond to your request as appropriate.
Your rights over your personal information depends on the Data Privacy Law applicable where you reside:
For additional information for residents of the State of California, click here.
The California Consumer Privacy Act of 2018 (“CCPA”) and California Privacy Rights Act of 2020 (“CPRA”) provide certain rights to residents of California. This section of the Privacy Notice applies if you are a natural person who is a resident of California (“California Consumer”) and use our Services. This notice supplements the information in the Privacy Notice. Certain terms used below have the meanings given to them in the CCPA and CPRA. The CCPA and CPRA shall be collectively referred to herein as the “CPRA”.
3. GDPR Privacy Rights
For additional information for residents of European countries, including the United Kingdom and Switzerland, click here.
1. How to Exercise Your Rights
To submit a request to access, rectify, delete, port your personal data you can submit a request to us either:
● by email at [email protected]; or
● by calling us at 866-849-0817.
Note in the body of the email the specific right you want to exercise. In the subject line, include “
To protect the privacy and security of your personal information, we will attempt to verify your identity before acting on your request. Your request must include details sufficient for us to properly understand, evaluate, and respond to the request.
Please also note that as part of the verification process, we’re required to consider:
(a) the difficulty of verifying whether data that we hold and data we have linked to it truly and solely belongs to the data subject making the request, along with; and
(b) the potential adverse effects on disclosure of personal data to the wrong individual (or a person who is purposefully seeking the information of another) because such improper disclosure would likely adversely affect the privacy rights and freedoms of the relevant data subject/consumer, we limit certain personal data we make available.
2. Use of an Authorized Agent
An agent legally authorized to act on your behalf—may make a verifiable request related to your personal information. If you are making a request through an authorized agent, you must provide the authorized agent with written permission to do so, and a power of attorney that fulfills the requirements of the Data Privacy Laws. We may request more information from the authorized agent (or from you) if needed to verify the authorized agent’s identity or to avoid any breach of security or instances of fraud.
3. Minors
Most of the time we act as a “Service Provider” to other companies, our Customers — for instance, when we help other businesses use their own customers’ information as we provide our Services to them. As to personal information that we hold as a “Service Provider,” you would generally need to reach out to the business (our Customer) or we will refer your request to them so they can act on your request to exercise your rights stated here.
IX. Changes to this Privacy Notice
X. Contact Us
If you have any questions, or complaints, regarding the collection or use of your personal information or the content of this notice, please contact our Privacy Officer at the coordinates below.
Privacy Officer
InhabitIQ
2035 Lakeside Centre Way, Suite 250, Knoxville, Tn 37922
[email protected]
We respect your privacy rights and commit to the security of your personal information. If you do not agree to how we process your personal information as discussed in this Privacy Notice, please reach out to us.