Effective Date January 1, 2020
INTELITY provides guest experience management services through mobile applications owned and operated by INTELITY, Inc. (“INTELITY”, “we” or “us”) (the “Service”). The Service includes the website located at https://www.intelity.com
Marketing & Communications Services
Information Collected as a Data Controller
INTELITY may collect the following Data, as a Data Controller (“Data Controller”) through INTELITY’s Platform, for marketing and communications purposes (Commercial Purposes). This Data can be used to directly or indirectly identify you:
- Your name
- Your email address(es)
- Your address
- Your phone number
- Your title
- Your IP address
The level of Data collected by INTELITY varies depending upon your request. INTELITY may collect your email address only or INTELITY may collect both your name and email address. INTELITY may also collect Data that cannot be used to identify you including anonymous usage Data and Platform Data for analytical purposes. For information on INTELITY anonymous usage data please see the Anonymous Data
User Access Rights
Under applicable Data Protection Laws, you may have the right to request access to your Data where your Data is controlled by INTELITY as the Data Controller (“Data Controller”). You may have the right to request that your Data controlled by INTELITY be corrected. You may have the right to request that your Data controlled by INTELITY be deleted from INTELITY’s systems. This process is also referred to as the ‘right to be forgotten’. INTELITY will comply with this request except where INTELITY is required by law or regulation to keep your Data. In such circumstances INTELITY will advise you as to this legal or regulatory obligation. Where INTELITY relies on your consent, to process your Data controlled by INTELITY, you may have the right to withdraw such consent to further use of your Data. In certain circumstances, you may have the right to object to INTELITY processing your Data. For example, you may unsubscribe from marketing messages or blogs to which you consented and subscribed by following the unsubscribe link or instructions contained in such messages or blogs. In certain circumstances, you may have the right to request that INTELITY transfer Data that you have provided to us to a third party. You may have the right to file a complaint with the local Data Protection Regulator if you believe that INTELITY has breached Data Protection Laws when using your Data. You may request access to Data collected and controlled by INTELITY by sending an email to email@example.com
Business and Operations Services
Information Processed as a Data Processor
INTELITY processes information in accordance with its business operations and in providing business services (the Business and Operations Services). Certain Data shared with INTELITY is based on a contractual agreement for Business and Operations Services between INTELITY and certain contractual third-parties providing Accommodations ( “Partner Accommodation(s)” or “Partner(s)”). Under this arrangement, the Partner is the Data Collector and INTELITY is the Data Processor (“Data Processor”); and Data is processed by INTELITY, through the Platform, in order to perform the Business and Operations Services. Examples of Data a Partner Accommodation may control and share with INTELITY to process include:
- Your name
- Your email address
- Your phone number
- Your scheduled arrival and departure date
- Your IP address
- Your profile picture and other Data shared through your registration for the Service via a Social Networking Site (“SNS”)
This Data is held on INTELITY’s systems but is not controlled by INTELITY. This Data is controlled by the Partner Accommodation, the originator of the Data, and in accordance with the contract and terms and conditions as set forth between you and the Partner Accommodation. Data that originates from the Partner is stored, and controlled, by the Partner on the Partner’s systems and environments. The Partner may share your Data with other third-parties (“Third-Parties”). INTELITY is not responsible for the maintenance or security of Data stored and controlled by such Partner Accommodation or Third-Parties. INTELITY will implement appropriate systems’ security measures designed to help ensure the confidentiality and security of Data held by INTELITY and protect against anticipated threats and unauthorized access to Data. For additional information on INTELITY’s security practices please see the Data Security
Cookies and Web Beacons
Necessary cookies help make INTELITY’s Platform usable by enabling basic functions like page navigation and access to secure areas of the Platform. INTELITY’s Platforms cannot function properly without these necessary cookies. INTELITY uses the following necessary cookies on its Platform:
- Cookies to store the user’s cookie consent state for the current domain.
- Cookies used by the content network, Cloudflare, to identify trusted web traffic.
Preference cookies enable a website to remember information that changes the way the website looks. Statistic Cookies
Statistic cookies assist INTELITY in understanding how users interact on digital platforms by collecting and reporting information anonymously. INTELITY uses Google Tag Manager and Google Analytics to:
- Collect data on the number of times a user has visited its Sites as well as dates for the first and most recent visit.
- Register a timestamp with the exact time of when the user leaves a Site.
- Calculate the duration of a Site visit.
- Throttle the speed of request to the server.
- Collect data on where the user came from, what search engine was used, what link was clicked and what search term was used.
Marketing cookies are used to track users across INTELITY’s Platform. The intention is to display content or ads that are relevant and engaging for the user and thereby more valuable for publishers and third-party advertisers. INTELITY uses marketing cookies from the following sources:
- Google Tag Manager
- Google Analytics
These marketing cookies are used to:
anonymous statistical data related to the user’s visits, such as the number of visits, average time spent visiting a website, and what pages have been loaded. These marketing cookies are also used to send data to the marketing platform HubSpot. HubSpot has the ability to look at user device information and behavior. Anonymous Data
INTELITY may share your non-personally identifiable information and click stream data with vendors that help us customize the advertising and marketing messages you receive as part of the Service. Anonymous click stream and demographic information may also be shared with Partner Accommodations, INTELITY advertisers and business partners. We may disclose non-identifying, aggregated User statistics to third-parties for a variety of purposes, including describing our services to prospective partners and other third-parties. Examples of such non-personal information include the number of Users who visited the Platform during a specific time period or purchased a specific product through the Platform. How to Remove Cookie Tracking
You have a choice whether to accept cookies, however, if you reject cookies or if cookies are disabled on your web browser, some parts of INTELITY’s Platform may not be operable. You can exercise your cookie preferences by clicking on the appropriate opt-out links provided. You can also manage cookie settings from within your browser. For your convenience information from the browsers on how to manage cookies from your desktop is provided below:
And if you want to manage cookies from your mobile device:
For additional information and/or specific questions related to INTELITY’s cookies policy please contact firstname.lastname@example.org
INTELITY may disclose Data in order to protect the legal rights of INTELITY, its affiliates or their employees, agents and contractors; to protect the safety and security of visitors to our Platform; to protect the rights, property or safety of INTELITY; or when legally required to do so, at the request of governmental authorities conducting an investigation, or to verify or enforce compliance with the policies governing the Service and applicable laws. Where you ask INTELITY to stop using your Data, INTELITY will honor your request, but we will retain any record of your Data as necessary to comply with applicable federal, state or local law.
Sale or Transfer
If INTELITY sells all or part of its business, makes a sale or transfer of assets or is otherwise involved in a merger, business transfer or other fundamental corporate change INTELITY reserves the right to disclose, share and/or otherwise transfer User information, including without limitation, Data to a third-party as part of such transaction.
If you choose to participate in an INTELITY promotion, your Data may be disclosed to third-parties in connection with such promotion, including without limitation for purposes of posting your entry with attribution or otherwise as permitted in the official rules for the promotion in question, fulfilling your prize or including your name on a winners list. Also, by entering a promotion, we may require you to consent to the use of your Data, such as name, voice or likeness, in advertising, promotional and marketing materials. In addition, we may offer certain promotional content sponsored by or co-branded with a third-party, who may obtain the Data that you submit.
INTELITY holds the confidentiality, integrity, and availability of your Data in the highest regard. We use various security measures to protect Data that we collect, and we have implemented security measures as part of INTELITY’s program to protect Data it controls. All Data stored in the INTELITY platform is encrypted. INTELITY conducts background checks on employees, utilizes web application firewalls, employs secure coding practices based on industry best practices, and performs vulnerability scans and application penetration tests on its environment as part of its risk management process. Unfortunately, no security measures are perfect or impenetrable and data transmission over the Internet cannot be guaranteed to be 100% secure. We cannot and do not ensure or warrant the security of any information you transmit to INTELITY and you do so at your own risk.
Notification of Changes
Special Notice Regarding Minors
INTELITY respects the privacy of children of all ages and in particular recognizes the sensitivity of Data concerning children under the age of 13 (“Minors”) and therefore provides this special notice to parents and legal guardians regarding the collection and use of Data collected from Minors. The Service is not directed toward Minors. If you are over the age of 13 but under the age of 18, you should use the Service only with the involvement of a parent or legal guardian and should not submit any Data to INTELITY. If we discover that a Minor has provided us with Data, INTELITY will use commercially reasonable efforts to delete such Minor’s Data from its system.
. Or you may write to us at:
600 Wilshire Boulevard, Suite 700 Los Angeles, CA 90017 Attention: Legal Department
Notice to California Residents
If you are a California resident, under the California Consumer Privacy Act (CCPA) you have additional rights related to your Data. Right to Know.
You have the right to know and see what Data INETELITY has collected about you over the preceding 12 months, including:
Right to Delete.
- The categories of Data INTELITY has collected about you;
- The categories of sources from which Data is collected;
- The Business and Operations Services purposes for collecting your Data;
- The Commercial Purposes for collecting your Data;
- The categories of third parties with whom INTELITY has shared your Data; and
- The specific pieces of Data INTELITY has collected about you.
You have the right to request that INTELITY delete the Data we have collected from you and direct our Partners to do the same. Deletion of your Data is not an absolute, however. There are exceptions under which INTELITY may retain your Data and where INTELITY is not required to delete your Data. Business and Operations Services Exception
INTELITY may retain your Data for the following Business and Operations Services:
You may not opt out of the use of your Data for Business and Operations Services Commercial Purposes
- In order to process paperwork in connection with a Service
- As part of the business operations in servicing your account
- To share with an Affiliated Company that is providing services on behalf of INTELITY
- To improve the products and services currently offered or that may be offered in the future by INTELITY
- To comply with legal or regulatory inquiries; or responding to court orders.
INTELITY may collect Data from you for the following Commercial Purposes:
You may opt-out of the sharing of your Data for Commercial Purposes. Exercising Your California Data Privacy Rights.
- For marketing and sales purposes in offering INTELITY’s products and services;
- For third-parties with whom INTELITY has contracted for Service.
To request access to or deletion of your Data, or to exercise any other data rights under California law, you may contact INTELITY using any of the following methods:
Response Timing and Format.
- Authenticate and exercise your Data privacy rights, click here and click on “Data Questions for CA Residents.”
- Contact us via our toll free dedicated California Data Privacy line: (888) 401-1354.
INTELITY will respond to a CA consumer request for access or deletion (Request) within 45 days of receiving that Request. If INTELITY requires more time, we will inform you of the reason and extension period in writing.