Direct Software Privacy Notice

GLOBAL PRIVACY POLICY FOR YOUR SECURITY AND CONFIDENTIALITY

Last Updated/Effective Date: March 17, 2021

Greetings! Our team here at Vacation Rental Partners, Inc. (“Direct” or “VRP”) values your trust and makes it a high priority to ensure the security and confidentiality of the personal information you provide to us. Below you will find our Privacy Notice (“Notice”). We encourage you to please read this Notice to learn about our privacy practices so you can better understand what we collect from you, why we collect it and your rights. By accessing or using our site, our services, or contacting us, you acknowledge that you have read, understood, and agree to the practices as described in this Notice. This Notice may change from time to time (see Changes to our Privacy Notice below). Your continued use of our website or services after we make changes is deemed to be acceptance of those changes, so please check our Notice periodically for updates.

What information do we collect?

We collect personal information from you directly when you register on our site, execute an order form for our services, subscribe to our newsletter, respond to a survey, or fill out a form or input data on our site. In such cases, you may be asked to enter certain personal information including your name, e-mail address, mailing address, and phone number.

When you use our site, we and our third party service providers may also automatically collect information about your device or use of the site or services, including the following:

• IP address (a unique identifier for your computer or other device)
• Mobile device ID
• Services navigation history and habits
• Browser type and language
• Internet service provider (ISP)
• Operating system
• Date/time stamp
• Clickstream data
• Cookies (text files containing small amounts of information which we download onto your computer or device when you visit our website, allowing us to remember you)

Finally, we may collect data about you through our own, or third party, analytics services or other data provider services. For example, we may use Google’s analytics services to determine how you found our website. Or, as another example, if you tell us your company name, we may research your company through third party services.

Information you actively provide us –

Registration information. Our system 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.

Content. Your use of our system 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. Our service is particularly aimed for properties listed on and operating through third party platforms such as Airbnb, HomeAway, VRBO, Booking.com, etc (“Third Party Channels”). After you register, you may interconnect our system 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 our service and your interactions with our system’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.

How do we use your information?

Any of the information we collect from you may be used in one of the following ways:

• To personalize your experience (your information helps us to better respond to your individual needs)
• To market our services to you
• To improve our website (we continually strive to improve our website offerings based on the information and feedback we receive from you)
• To improve customer service (your information helps us to more effectively respond to your customer service requests and support needs)
• To administer a contest, promotion, survey or other site feature
• To send periodic emails
• For our other business purposes
• Operating our service and providing its features and functionalities
• Sending you notifications, messages, communications and announcements related to our service
• Improving and customizing our 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 Notice and preventing misuse of our 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 our service

We also may collect and store information about you that we receive from other sources to, among other things, enable us to verify, update and correct the information contained in our databases, prevent fraud, provide services to our other clients, and to better customize your experience on our site.

Note: If at any time you would like to unsubscribe from receiving future marketing emails, please contact help@getdirect.io.

How do we protect your information?

VRP has implemented reasonable physical, technical, and administrative security standards to protect personal information from loss, misuse, alteration, or destruction. We strive to protect your personal information against unauthorized access, use or disclosure, using security technologies and procedures, such as encryption and limited access. Only authorized individuals access your personal information, and they receive training about the importance of protecting personal information.

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.

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.

Access from outside the United States

If you access our site or use our services from outside the United States, please be aware that personal information may be transferred to, stored in, and processed in the United States. Certain governmental authorities may not consider the level of protection of personal information in the United States to be equivalent to that required by the in other jurisdictions.

Do we use cookies and interest-based advertising?

Yes, cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow) that enables the sites or service providers systems to recognize your browser and capture and remember certain information.

We use cookies to help us understand and save your preferences for future visits, keep track of advertisements, market our services, and compile data about site traffic and site interaction so that we can offer better site experiences and tools in the future. We may contract with third-party service providers to assist us in better understanding our site visitors.

If you prefer, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies via your browser settings. Like most websites, if you turn your cookies off, some of our services may not function properly. However, you can still reserve a booking over the telephone by contacting the company’s customer service number directly. Your browser or device may include “Do Not Track” functionality. Our websites and services do not recognize “do not track” signals or similar mechanisms that allow browser users to make a choice about the collection of information that reveals the individual’s online activities, so VRP’s information collection and disclosure practices and the choices we provide will continue to operate as described in this Privacy Notice, whether or not a Do Not Track signal is received.

We may allow third-party advertising companies to collect certain information when you visit our site. These companies may utilize cookies, pixels or other technologies to collect and use non-personally identifiable information (e.g., hashed data, browser type, time and date, subject of advertisements clicked or scrolled over) during your visits to this and other websites in order to provide advertisements about goods and services likely to be of greater interest to you (i.e. interest-based advertising). They may also use persistent identifiers to track your Internet usage over time and across other websites in their networks beyond our site. To learn more about interest-based advertising or to opt-out of this type of advertising, you can visit the websites of the Digital Advertising Alliance at http://aboutads.info and Networking Advertising Initiative at http://networkadvertising.org/choices. Google, as a third-party vendor, also uses cookies to serve ads. Google’s use of the DART cookie enables it to serve ads based on your visits to VRP’s sites and other sites on the Internet. Users may opt out of the use of the DART cookie by visiting the Google ad and content network privacy policy.

Do we disclose any information to outside parties?

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

• With contractors and service providers, in order to operate, maintain and enhance the site and our services
• With third party integration partners in connection with your use of the services
• If you have breached the Terms, abused your rights to use our system or violated any applicable law, your personal 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 system is organized within a different framework, or through another legal structure or entity (such as due to a merger or acquisition)
• We may share personal information with our affiliates who have a need to know the information for our business purposes

We may also disclose your personal information when we believe it is necessary to comply with the law, enforce our site’s policies, or protect our or others’ rights, property, or safety in anyway legally or most appropriate to the situation.

We may share your personal information with our business partners or co-marketers from time to time. . Non-personally identifiable or aggregated information may also be provided to other third parties for marketing, advertising, or other uses.

Third-party links

Occasionally, at our discretion, we may include or offer third party products or services on our website. These third party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites.

Individuals Within the European Union

Legal Bases for Processing Personal Data

If you are an individual located in the European Union (EU), we collect and process personal data about you where we have a legal basis for doing so under applicable EU laws. This means we collect and process your data only when:

• it is necessary for a legitimate interest (which is not overridden by your individual privacy interests), such as preventing fraud, improving our site, and increasing the security of the website and network infrastructure;
• you have consented to this collection and processing for a specific purpose;
• it is necessary to fulfil our contractual obligations; or
• it is necessary to comply with a legal obligation.

Where we rely on your consent to process your personal data, you have the right to withdraw or decline consent at any time. Some examples of where we rely on your consent to process your personal data include sending you marketing emails. If you wish to withdraw your consent, please contact us at help@getdirect.io.

Some examples of our legitimate interests for processing personal data include:

• site and network security;
• customer support;
• fraud prevention; or
• improving our site.

Where we rely on our legitimate interests to process your personal data, you may have the right to object. More information on exercising this right can be found in the Individual Rights section below.

If you have any questions about or need further information concerning the legal basis on which we collect and use your personal data, please contact us at help@getdirect.io.

Individual Rights

If you are located in the EU, you have certain rights under EU data protection law with respect to your personal data, including the right to request access to, correct, and delete your personal data. You may also have the right to receive a copy of your personal data in a commonly used and machine-readable format, and to transmit such data to another controller. You also may object to processing of your personal data, or ask that we restrict the processing of your personal data in certain instances.

To request deletion of, access to, or to make changes to your personal data, or to otherwise any of the rights in this section, please contact us at help@getdirect.io. Please note that not all requests can be honored.

Transfers, Storage, and Processing

Our site is operated from and hosted on servers located in the United States. If you access and use our website from a location outside of the United States, any personal data you provide to us or that is otherwise collected may be transferred to and processed in the United States or any other jurisdiction in our sole discretion. Users of our Apps should be aware that the laws that apply to the use and protection of personal data in the United States or other countries or jurisdictions to which we transfer, or in which we process, personal data may differ from those of your country of residence. Users who access or use our site from jurisdictions outside of the United States do so at their own choice and risk and are solely responsible for compliance with local law. While we take steps to safeguard your personal data, the United States has NOT been deemed by the European Commission to ensure an adequate level of protection for personal data. Accordingly, the level of protection provided in the United States or other non-EU countries and jurisdictions from which you may access our Apps may not be as stringent as that under EU data protection standards or the data protection laws of some other countries, possibly including your home jurisdiction.

If we are processing your personal data on behalf of another party, your personal data is transferred across borders to the United States or to other countries or jurisdictions in which we or our third-party associates may process personal data through the use of Standard Contract Clauses.

Unresolved Complaints

If you are a resident of the EU and your inquiry with us has not been satisfactorily addressed, or if you believe we are processing your personal data not in accordance with the law or this Privacy Policy, you may file a complaint with the supervisory authority in your country of residence.

California Residents

California Civil Code Section § 1798.83 permits users of our site that are California residents to request certain information regarding VRP’s disclosure of their personally identifiable information to third parties for those third parties’ direct marketing purposes. To make such a request, please send an e-mail to help@getdirect.io specifying that you seek your “California Customer Choice Notice.” In your request, please attest to the fact that you are a California resident and provide a current California address for your response. Please be aware that not all information sharing is covered by these California privacy rights requirements and only information on covered sharing will be included in our response. This request may be made no more than once per calendar year. Please allow up to thirty days for a response.

Children’s Information

VRP does not offer its services to children under the age of 18. If you are not at least 18 years old, you may not use our site or services. We do not knowingly or intentionally collect personal information about children who are under 13 years of age. If you believe that VRP has been provided with the personal information of a child under 13 without parental consent, please notify us immediately at help@getdirect.io.

Change in Ownership

We may change our ownership or corporate organization while providing our sites or services. We may also sell certain assets associated with the sites or services. As a result, please be aware that in such event we may transfer some or all of your personal information to an entity acquiring all or part of our assets or to another entity with which we have merged. We cannot promise that the acquiring or merged company will have the same privacy practices or treat your information the same as described in this Notice.

Changes to our Privacy Notice

We reserve the right to modify or amend the terms of this Notice from time to time. Your continued use of our sites or services following the posting of changes will mean you accept the new Notice as modified. If we decide to change our Notice, we will post those changes on this page and they will be effective immediately.

Contacting Us

If there are any questions regarding this Notice you may contact us using the information below.

Vacation Rental Partners, Inc.
https://www.directsoftware.com
1588 S Main St, #102
Salt Lake City, UT, 84115
Email: help@getdirect.io
1 (312) 878-4572
1 (844) 829-7829