Privacy Policy

DATA COVERED BY THIS PRIVACY STATEMENT
This Privacy Statement describes the privacy practices of the Halo Holiday Rentals for data that we collect:

– through websites operated by us from which you are accessing this Privacy Statement, including Halo Holiday Rentals and other websites owned or controlled by the Halo Holiday Rentals (collectively, the Websites );
– through the software applications made available by us for use on or through computers and mobile devices (the Apps );
– through our social media pages that we control from which you are accessing this Privacy Statement (collectively, our Social Media Pages );
– through email messages that we send you that link to this Privacy Statement and through your communications with us online or in person;
– from third parties such as Authorized Licensees, Owners and Franchisees and Other Sources, such as public databases, marketing partners and other third parties; and
– when you visit or stay as a guest at one of our properties, or at homes and villas offered on the Halo Holiday Rentals platform, or through other offline interactions (collectively, Property Visits and Offline Interactions ).

Collectively, we refer to the Websites, the Apps, and our Social Media Pages, as the “Online Services” and, together with the Property Visits and Offline Interactions, the “Services.”

THE DATA WE COLLECT
At touchpoints throughout your guest journey, we collect Personal Data in accordance with the law, and to serve you better. Personal Data is information that may identify you as an individual or relate to you as an identifiable individual. We collect and process the following types of Personal Data about you:

– Name
– Gender
– Postal address
– Telephone number
– Email address
– Financial information (such as credit and debit card number or other payment data)
– Language preference
– Date and place of birth
– Nationality, passport, visa, or other government-issued identification data
– Important dates: birthdays, anniversaries, and special occasions
– Membership or loyalty program data (including co-branded payment cards, travel partner program affiliations)
– Employer details (for business-related bookings)
– Travel itinerary, tour group, or activity data
– Prior guest stays or interactions, goods and services purchased, special service and amenity requests
– Social media account ID, profile photo and other data publicly available, or data made available by linking your social media and loyalty accounts

In more limited circumstances, we may also collect:

– Data about family members and companions, names, and ages of children
– Biometric data
– Images, video and audio data via: (a) security cameras located in public areas, such as hallways and lobbies, in our properties; and (b) body-worn cameras carried by our loss prevention officers and other security personnel

We may also collect information about your Preferences that we use to make your current and future stays and experience with us more enjoyable, including information about your interests and other relevant information that we learn about you during your stay. This may also include any likes and dislikes about our services that you tell us about so that we can improve our services, and health restrictions or personal needs to ensure your wellbeing. We may also collect your “Personal Preferences,” that may include details of your special anniversaries (such as your birthday or wedding anniversary), what type of activities you prefer to take part in when staying with us, and your hobbies. Personal Preferences may also include details about who you usually travel with, their relationship to you, and your marital status.

If you submit any Personal Data about other people to us or our Service Providers (e.g., if you make a reservation for another individual), you represent that you have the authority to do so and you permit us to use the data in accordance with this Privacy Statement.

COOKIES
We collect certain data from cookies, which are pieces of data stored directly on the computer or mobile device that you are using. Cookies allow us to collect browser type, time spent on the Online Services, pages visited, referring URL, language preferences, and other aggregated traffic data. We use functional cookies to obtain the data for security purposes, to facilitate navigation, to display content more effectively, to collect statistical data, to personalize your experience while using the Online Services, and to recognize your computer to assist your use of the Online Services. We also gather statistical cookie data about use of the Online Services to continually improve design and functionality, understand how they are used and assist us with resolving questions. Advertising cookies further allow us to select which advertisements or offers are most likely to appeal to you and display them while you are using the Online Services. We also use them to send marketing emails and to track responses to online advertisements and marketing emails.

Manage Cookie Preferences:
You can choose whether to accept cookies by managing your tracking preferences by clicking on “Tracking Preferences” located at the bottom of our home page or by changing the settings on your browser. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Online Services. For example, we will not be able to recognize your computer, and you will need to log in every time you visit. You also will not receive advertising or other offers from us that are relevant to your interests and needs. At this time, we do not respond to browser “Do-Not-Track” signals.

HOW AND WHEN WE SHARE YOUR DATA
Our goal is to provide you with the highest level of hospitality and Services, and to do so, we may share Personal Data and Other Data with the following:

Halo Holiday Rentals: We disclose Personal Data and Other Data to other companies within the [Halo Holiday Rentals Group] for the purposes described in this Privacy Statement, such as providing and personalizing the Services, communicating with you, facilitating the loyalty programs and to accomplish our business purposes. We share your Personal Data and Other Data used for making reservations with the applicable property and Halo Holiday Rentals entity to fulfil and complete your reservation.
– Franchisees. We disclose Personal Data and Other Data to Franchisees of Halo Holiday Rentals Group branded properties for the purposes described in this Global Privacy Statement. Franchisees have a limited right to use certain Personal Data for their own purposes and therefore qualify as independent data controllers for the following processing: Franchisees manage and coordinate your stay at hotels that they operate so they may use your Personal Data for that purpose. Franchisees may also use your Personal Data for compliance with their own legal obligations, including maintaining books & records and other compliance obligations.
– Owners: We disclose Personal Data and Other Data to Owners of Halo Holiday Rentals Managed properties for the purposes described in this Global Privacy Statement. Owners have a limited right to use certain Personal Data for their own purposes and therefore qualify as independent data controllers for the following processing: Owners may use your Personal Data for complying with their own legal obligations, including maintaining books & records and other compliance obligations.
– Authorized Licensees. Where allowed by law we disclose Personal Data and Other Data to our Authorized Licensees, branded real estate, co-branded credit cards and banks, for the purposes described in this Privacy Statement, such as providing and personalizing the Services, fulfilling your requests and providing their own marketing.
– Promotional Activity. We partner with third parties who may provide promotions to you.
– Service Providers. We disclose Personal Data and Other Data to third party service providers including, for example, companies that provide website hosting, data analysis, payment processing, order fulfilment, information technology and related infrastructure provision, customer service, email delivery, marketing, auditing, and other services.

OTHER IMPORTANT PROVISIONS

Non-Halo Holiday Rentals Group Entities
This Privacy Statement does not address, and we are not responsible for the privacy, data, or other practices of any entities outside of the Halo Holiday Rentals, including Franchisees, Owners, Homes and Villas Property Management Companies, Authorized Licensees, Strategic Business Partners, or any third party operating any site or service to which the Services link, payment service, loyalty program, or website that is the landing page of the high-speed Internet providers at our properties. The inclusion of a link on the Online Services does not imply endorsement of the linked site or service by us. We generally have no control over, and are not responsible for, any third party’s collection, use and disclosure of your Personal Data.

In addition, we are not responsible for the data collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Data you disclose to other organizations through or the Apps or our social media pages.

Security
We seek to use reasonable organizational, technical, and administrative measures to protect Personal Data. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us.