Posting Date: November 19, 2019
Effective Date: December 2, 2019
1. What Information Is Collected By Hello! Or Our Service Providers And When
We may collect personal information through physical media (e.g., paper forms), electronic communications (e.g., email or electronically submitted forms), and/or on the Sites. Personal information includes data that specifically identifies you, such as your name, email address, mailing address, telephone number, and payment information. We may collect personal information from you actively (i.e. by collecting information you voluntarily submit to us) and passively (i.e. by collecting information automatically gathered from your computer). For example, certain portions of the Sites may require registration for access. As part of registration, and/or for the provision of services, we may ask you to provide us with personal information.
If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.
You may provide us and/or our service providers personal information in a number of ways, for example by completing and sending to us a paper form, transmitting to us an electronic copy of a completed form, by entering information into data fields provided in electronic forms on the Sites (e.g., by creating an account), or in communications with us using the contact information in Section 14 below.
Hello! and its service providers also collect certain non-personal information, data that does not identify you as an individual person. This information tells us about how people use the Sites so that we can analyze its effectiveness and provide you with a better web experience. We collect and use this information through a variety of technologies, including “cookies” and analysis applications, as discussed below.
(a) Server Information
Like every website, the servers hosting the Sites may automatically and temporarily store the following information in the server log files. The following information may be provided by your browser, unless you have deactivated the function:
- IP address of the enquiring computer
- File query by the client
- The http response code
- The Internet page from which you visited us (referrer URL)
- The time of the server query
- The browser type and version
- The operating system used on the enquiring computer
The server log files are not analysed with respect to individuals. At no time can this data be attributed to specific individuals.
(b) Site Visit Tracking Technologies
A cookie is a unique alphanumeric identifier that websites use to help identify the number of unique visitors to a website, whether or not those visitors are repeat visitors, and the source of the visits. Cookies cannot be executed as code or used to deliver a virus and thus pose no threat to you. Servers and sites other than the one placing the cookie on your hard drive cannot read the cookie, and no personal information can be gathered by other servers from the cookie. If you prefer not to enable cookies or to disable them, you may do so through your web browser’s security settings. Please note that certain features of the Sites may not be available once cookies have been disabled.
As with most websites, the servers hosting the Sites gather certain information automatically and store it in log files. This information includes internet protocol (“IP”) addresses, browser type, operating system, internet service provider (“ISP”), referring/exit pages, date/time stamp of access, and clickstream data, and information about the content you view on the Sites. When you visit a Site, the servers automatically log your IP address, the time and duration of your visit, and the time and duration spent on the pages of the Sites which you view. If you arrive at the Sites by clicking a paid advertisement or a link in a communication, then the server will capture information that tracks your visit from that link. If you arrive at the Sites by clicking on a non-paid source, such as a search engine result or link on another website, the server may capture information that tracks your visit from that source, to the extent available.
Some of our communications to you may contain a “click-through URL” which links to content on the Site. When you click one of these URLs, it passes information through the Hello! servers before you arrive at the destination web page. Hello! tracks this click-through data to help determine interest in particular topics and measure the effectiveness of our communications. If you prefer not to be tracked, simply avoid clicking text or graphic links in emails you receive from Hello!.
Certain features of the Sites may use local stored objects (“Flash cookies”) to collect and store information about your preferences and navigation to, from, and on our website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
Hello! additionally may use web beacons or pixel tags, which are tiny invisible graphic images, in the Site. Web beacons and pixel tags may be used by Hello! to count users who have visited its webpages and for related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
(c) Different Devices
If you use different devices (e.g., your smart phone, laptop, and/or home computer) to access a Site, we may be provided with and collect device-specific information, including your hardware model, operating system version, unique device identifiers, phone number, location, and mobile network information. We may associate your device identifiers or phone number with your account information.
(d) Third-Party Analytics
We may use third-party service providers (e.g., search engines) to collect and analyze information about your use of the Site(s). These service providers may utilize cookies and related technologies to collect personal information.
2. Use of Information
Hello! and our service providers may use your personal information to provide our services and to contact you in response to inquiries you submit. Hello! and our service providers may use your personal information to manage our contractual relationship with you, because we have a legitimate interest to do so, and/or to comply with a legal obligation. For example, we may use your personal information to:
- present our Sites and related content to you;
- provide you with information, products or services that you request from us;
- provide you with notices about your account;
- in combination with other information, improve the Sites and/or for marketing or promotional purposes;
- provide more consistent and personalized services across the Sites, including to personalize our advertising, marketing, and promotional efforts;
- carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
- notify you about changes to the Sites or any products or services we offer or provide though it;
- allow you to participate in interactive features on the Sites.
On occasions where we ask you for consent, we will use the information for the purposes which we disclose at that time. You have the right to withdraw your consent at any time; however, we may have other legal grounds for processing your personal information, including those identified above.
3. When Hello! Discloses Your Information
We may disclose aggregated information about our users without restriction. Such aggregated user data cannot be attributed to any specific individual. Hello! may disclose aggregated user data in order to describe our services to current and prospective affiliates, and to other third parties for lawful purposes.
Hello! and its service providers may transfer information between them for business purposes. For example, our service providers may handle technical support, payment processing, marketing, advertising delivery and tracking, or information analysis. We furnish our service providers with only the personal information they need to perform these and other services, and we work with our service providers to respect and protect your personal information. We may also provide your personal information to our affiliates. The entities with which we share your personal information may be located in the United States or other countries.
In the event that Hello! or some of our assets are sold, transferred, or used as security, or to the extent we engage in business negotiations with our business partners, personal information collected on the Sites may be transferred or shared with third parties as part of that transaction or negotiation. We may also provide personal information or provide access to personal information to any of our affiliated businesses or business partners.
On rare occasions, we may disclose specific personal information without your consent and without notice to you if required to comply with laws and regulations, or to comply with court orders, subpoenas, or lawful discovery requests. Information collected from you may also be used to investigate security breaches or otherwise cooperate with authorities. We may also share personal information with companies assisting in fraud protection or investigation.
4. How Your Information is Protected
Hello! has implemented reasonable physical, technical, and organizational safeguards to help protect your personal information from unauthorized access, acquisition, or disclosure, alteration, or destruction. Although we strive to keep your personal information secure, no safeguards can be guaranteed to be completely secure, so you should exercise caution when transferring personal and other sensitive information over the Internet. Please advise us immediately at one of the contacts listed in Section 14 of any incident involving the loss of, unauthorized access to, or disclosure of personal information that is in our custody or control.
5. Third-Party Sites
The Sites may contain links to other websites. Please note that when you click on one of these links, you will leave the Site and will be subject to the policies and privacy practices of the other websites, which may differ significantly. You should review the policies of other websites you visit. Hello! is not responsible for the content, technology, security, or practices of linked sites operated by others, or for your use of linked sites.
6. Children’s Privacy
The Sites are not aimed at or intended for children. We do not knowingly collect information from children under the age of thirteen through the Site. If we obtain actual knowledge that we have inadvertently collected personal information relating to a child under the age of thirteen, we will delete that information from our records. If you believe we might have any information from or about a child under the age of thirteen, please contact us at firstname.lastname@example.org.
7. Applicable Law
We recognize that the Sites may be accessed from anywhere in the world, and that the laws of the jurisdictions in which some users are located may differ substantially from those of the United States and the State of Florida. Because we cannot practicably prevent users in different jurisdictions from accessing the Site, you are responsible for knowing and complying with the laws of your jurisdiction. If such laws conflict with your use of the Sites or any of its content or functionality, the Sites is not intended for you, and we ask you not to use it or submit any information through it.
8. Do Not Track
“Do Not Track” is a privacy setting that you may set in your web browsers. If turned on, this setting request that websites not track information about users. At this time, we do not respond to “Do Not Track” browser settings or signals.
9. Data Retention
We retain personal information for as long as necessary to provide services to you and fulfill the transactions you have requested, or for other necessary purposes such as complying with our legal obligations and enforcing our agreements. Retention periods vary depending on the type of information and how it is used. The criteria we use to determine the appropriate retention periods include:
- How long we have a relationship with you and provide services or products to you.
- Whether there is a legal, contractual or similar obligation that requires us to keep your information for a certain period of time.
- Whether you have consented to retention of your information for a longer period of time.
- Whether the personal information is sensitive.
When we no longer need to use or retain your personal information, we will remove it from our systems or depersonalize it so that it cannot be used to identify you.
10. Rights to Access and Control Your Personal Information
You have choices about the collection, use, and sharing of your personal information, including:
- Deletion: You can request that we erase or delete all or some of your personal information. We will do so in accordance with Data Retention policies described in paragraph 9 above.
- Change or Correct: Where applicable, you can review and edit your personal information by logging onto the Sites and visiting your account. You may also send us an email at email@example.com correct any personal information that you have provided to us.
- Object to or Restrict Use: You can request that we stop using some or all of your personal information or restrict our use of your personal information.
- Access and/or Take: You can request a copy of your personal information.
- Withdrawing Consent: If we have collected or processed your personal information with your consent, you may withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information based on other lawful processing grounds.
To learn more about how to make these requests, please contact us at firstname.lastname@example.org.
Notice to California Residents
If you are a California resident, you are entitled to request certain information regarding our disclosure, if any, of your personal information (such as your name and contact information) to third parties for their direct marketing purposes. If you are a California resident and would like to request a copy of information regarding our disclosure to third parties for their direct marketing purposes in the preceding calendar year, please contact us at email@example.com, or at the address listed in Section 14.
11. Cross-Border Transfers
We may transfer your personal information to other countries in compliance with applicable laws. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those countries may have access to your personal information.
14. Contact Us
Hello! Destination Management, 3840 Vineland Road, Suite 200, Orlando, FL 32811.
* Hello! Destination Management includes Hello! Florida Destination Management, Inc., Hello! Arizona Destination Management, Inc., Hello! Las Vegas Destination Management, Inc., Hello! Washington DC Destination Management, Inc., Hello! Texas Destination Management, Inc., Hello! Nashville Destination Management, Inc., Hello! California Destination Management, Inc., Hello! Colorado Destination Management, Inc. and Hello! Destination Management, LLC.