Under the California Consumer Privacy Act of 2018 (CCPA), (effective January 1, 2020), California residents possess rights to know what personal information is collected about them, including whether it is being sold or disclosed to third parties.
The CCPA also prevents companies from seeking reprisal against consumers for exercising those rights. Reprisal can come in several methods such as but not limited to denial of goods and/or services, price fixing, or providing a different quality/level of services or goods.
This notice applies to all activities of JMA Ventures, LLC, HPSF Holdings VII, LLC and all other members of the JMA Ventures family of businesses (altogether, referred to hereafter as “JMA”).
The types of personal information being collected or disclosed within the previous few years depend on the relationship with JMA and is subject to change. If such relationship with JMA changes, a subsequent data privacy notice may apply and will be provided to you.
We know that you care how information regarding you is collected and used. We take extreme pride in the relationships that we have developed with our guests and are committed to treating personal information we collect with utmost respect and care.
SCOPE OF THE POLICY
- This Policy applies to the personal information we collect when you visit any JMA web site where the Policy is posted (our “Sites”). When we use the term “personal information,” we mean information that identifies a particular individual, such as the individual’s name, postal address, e-mail addresses, and telephone number. When other information (such as consumer preferences or demographic information) is directly associated with personal information, this other information is treated as personal information.
- CONSENT TO THE POLICY
By visiting any of our Sites, you agree to the collection, use and disclosure of your personal information as described in this Policy. If you do not consent to the collection, use and disclosure of your personal information as described in this Policy, you should not use our Sites.
- PERSONAL INFORMATION WE COLLECT AND HOW WE USE ITWe collect the following types of personal information through our Sites:
Information You Actively Provide.We collect the personal information you actively provide when you use one of our Sites. We use the personal information you provide to deliver the programs, products and services that you request, or to process purchases or reservations you have made on our Sites. For example, we use the information you provide when you request additional information or contact to facilitate contact with you regarding such request. Information you provide to us on our Sites may be stored in an online profile we create for you, to enable us to better meet your needs and understand your preferences. Depending on your privacy preferences, we may use your personal information to send you promotional messages and special offers. We also use your personal information for security and fraud prevention purposes; to better understand our guests; to improve our programs, services, and Sites; and to better market and advertise our programs and services.
We may combine information you have provided to us on our Sites with information you have provided to us offline, and we may store this information together in your online profile. This enables us to better understand and meet your needs when you visit our resorts or other properties.
Information Provided by Others
From time to time, we may supplement the information you give us with information from third parties. For example, we may supplement your profile with demographic and preference data or we may correct mailing addresses by using public sources. By supplementing your profile, we are better able to provide product recommendations and special offers that will be of genuine interest to you. We may also use this information to further customize our Sites and improve the experience while you (or others) are on our Sites.
Information Sent to Us by Your Web Browser
We collect information that is automatically sent to us by your web browser. This information typically includes, but is not limited to: your IP address; the name and version of your operating system; the name and version of your browser; the page you were visiting before you accessed our Site; and the date and time of your visit. The information we receive depends on the settings of your browser. Please check your browser if you want to learn what information your browser sends or how to change your settings. Generally, we use this information to create statistics that help us improve our Sites and make them more compatible with the technology used by our visitors. This information is also used for marketing purposes and to improve your experience on the Sites.
We may collect IP addresses for purposes of system administration, to report traffic data to our corporate partners, and to audit the use of our Sites. Although the information provided by your browser does not identify you personally, this data can be combined with other data to personally identify you.
We may hire other companies to place our banner ads on other websites. Those companies may perform tracking and reporting activities on the ads they serve for us, as well as user reaction. They would not collect any information other than IP addresses and behaviors associated with those IP addresses on our behalf, and we will not give any personal information to them. Third-party advertising servers are subject to their own privacy policies. Our service providers are bound by contract to keep your personal information confidential and use it only to perform services on our behalf.
- DISCLOSURE OF YOUR PERSONAL INFORMATION
JMA currently does not sell your personal information to outside marketers or advertisers, but JMA reserves the right to sell, or assign our rights to, your personal information as allowed by applicable law. Under limited circumstances we may disclose the personal information we collect with outside parties for specific purposes. Those circumstances are described below along with some of the steps we take to limit the manner in which your personal information is used.
With Service Providers
We may share your information with companies that provide support services to us (such as credit card processors, mailing houses, web hosts, or providers of online reservation services) or that help us market our products and services (such as email vendors). These companies may need information about you in order to perform their functions. These companies are usually only authorized to use the personal information we share with them for the purpose of delivering the service we hire them to provide. In addition, we seek to only disclose the information they need to provide the specific service or function. We currently do not sell your personal information to third party marketing or advertising firms, but we reserve the right to do so to the extent allowed by applicable law.
With Other Companies in the JMA Family of Businesses
We may occasionally feature web pages on which you can register for special promotions or services provided in conjunction with our business partners. When we feature pages like these on our Sites, we will give you a clear notice that you are providing information to another party. We may also arrange to send you marketing and promotional information of other reputable companies that we think might be of interest to you, only if you tell us that you want to receive these sorts of materials. We do not share your personal information with these companies.
In Connection with Corporate Events
If some or all of the business assets of one of our companies or Sites are sold or transferred, we generally would transfer the corresponding information regarding our guests and customers (including your personal information) to the acquiring business so that they can continue to operate the business, but your information would remain subject to this Policy.
In Special Circumstances
In certain special cases, we may disclose your personal information when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing or threatening to cause injury to you, JMA or someone else. We may also disclose your personal information when we believe the law requires it, or in response to any demand by law enforcement authorities in connection with a criminal investigation, or civil or administrative authorities in connection with a pending civil case, administrative investigation or investigation conducted by JMA or its affiliates, contractors or assignees.
- LINKS TO THIRD-PARTY WEBSITES
- CHILDREN’S PRIVACY
We will not knowingly collect personal information on our Sites from children under the age of 13 without the prior consent of the child’s parent or guardian. If you believe that a child under the age of 13 may have provided personal information to us without consent of the child’s parent or guardian, please contact us at [firstname.lastname@example.org].
- YOUR CHOICES
Opt-Out of Receiving Future Communications We give you the opportunity to opt out of receiving direct marketing information from us. This means that we may use the information you provide for direct marketing or market research purposes unless you take affirmative action to indicate that you do not want to receive marketing materials, for instance by clicking or checking the appropriate option or box at the point of collection.Finally, you can opt out of receiving marketing information at any time. If you do not want to be included on our email or marketing list, you can easily opt out by sending an email clearly stating your request to opt out of specific e-mail or marketing list to [email@example.com].
Review and Update Your Information
You reserve the right to delete any personal or confidential information collected.
You may also review or update your personal information collected by this Site or correct factual inaccuracies by emailing a clear request to do so at [firstname.lastname@example.org].
- HOW WE PROTECT YOUR INFORMATION
JMA has reasonably appropriate physical, technological, and organizational safeguards and security measures in place to attempt to protect against the loss, misuse, unauthorized access or disclosure of your personal information under our control. However, it is important that you understand that no website or database is completely secure, or “hacker proof.” You can help us by protecting and keeping your passwords (if any) safe at all times. You can protect yourself and help us prevent computer crime by promptly notifying us if you suspect that your credit card, pass product with Resort Charge, user name or password is lost, stolen or used without permission. Also, you can reduce many risks by using up to date antivirus software.
- CHANGES TO THE POLICY
We may change this Policy from time to time at our sole and exclusive discretion and by posting the revised Policy on our Sites. The changes will only apply to the personal information we collect after we have posted the revised Policy. We will attempt to notify you of any significant changes to this Policy by sending an email notice if we have your e-mail address. However, it is your responsibility to check this Site for updates to the Policy as you will be bound by them if you choose to visit our Sites after such Policy updates become effective.
- VISITORS WHO ACCESS OUR SITES FROM OUTSIDE THE UNITED STATES
Our Sites and databases may be hosted on Web servers located in the United States or other countries. We share the personal information we collect with our third-party service providers, and others around the world as described in this Policy. When we transfer your personal information to another country, we will take appropriate measures to protect your privacy and personal information. By using one of our Sites, you are consenting to the transfer of your personal information to any country in the world in accordance with this Policy. The Sites are U.S. Sites and are governed by U.S. law. If you do not wish to consent to U.S. law or this Policy, you should not share information with us or use our Sites.
- YOUR CALIFORNIA PRIVACY RIGHTS
Pursuant to California Civil Code Section 1798.83, a California resident who has provided personal information to a business with whom he/she has established a business relationship has the right to request certain information regarding the disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please write or send an email to the contact information below.
- CONTACT US
JMA VENTURES, LLC
460 Bush Street
San Francisco, CA 94108