Last Updated: August 12, 2013
As used in this policy, the terms "using" and "processing" information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among our affiliates within the United States or internationally.
Information Collection and Use
Our primary goals in collecting information are to provide and improve our Sites, services, features and content, to administer your use of the Sites (together, the "Service") and to enable users to enjoy and easily navigate the Sites.
Personally Identifiable Information
When you register with us through the Sites to make a booking or when you wish to contact another user, we will ask you for personally identifiable information. This refers to information about you that can be used to contact or identify you ("Identity Information"). Identity Information includes, but is not limited to, your name, phone number, email address, social security number (SSN), and home postal address, but does not include your credit card number or billing information. In order to process some of your transactions through the Sites, we may also ask for your credit card number and other billing information ("Billing Information") (Identity Information and Billing Information together, "Personal Information"). Some Personal Information is required, like your name and email address, and other Personal Information is optional, like your date of birth. We reserve the right to require address confirmation for rentals included in our Services. We use your Personal Information to provide the Service and administer your inquiries. We collect Personal Information in connection with your registration to join the Service. You can register to join via the Sites by completing the required forms.
You can also register to join by logging into online accounts you may have with third party service providers ("SNS")(e.g. Facebook); each such account, a "Third Party Account", via our Sites as described below. As part of the functionality of the Service, you may link your TurnKey Account with Third Party Accounts, by either: (i) providing your Third Party Account login information to TurnKey through the Service; or (ii) allowing TurnKey to access your Third Party Account, as is permitted under the applicable terms and conditions that govern your use of each Third Party Account. You represent that you are entitled to disclose your Third Party Account login information to TurnKey and/or grant TurnKey access to your Third Party Account (including, but not limited to, for use for the purposes described herein), without breach by you of any of the terms and conditions that govern your use of the applicable Third Party Account and without obligating TurnKey to pay any fees or making TurnKey subject to any usage limitations imposed by the applicable SNS. If you decide to register by logging into a Third Party Account via our Sites, we will obtain the Personal Information you have provided to the applicable SNS (such as your "real" name, email address, profile picture, names of SNS friends, names of SNS groups to which you belong, other information you make publicly available via the applicable SNS and/or other information you authorize TurnKey to access by authorizing the SNS to provide such information) from your Third Party Accounts and use that information to create your TurnKey Account and TurnKey Account profile page and you will become a Member. Depending on the Third Party Accounts you choose and subject to the privacy settings that you have set in such Third Party Accounts, you understand that by granting us access to the Third Party Accounts, we will access, make available and store (if applicable and as permitted by the SNS and authorized by you) the information in your Third Party Accounts so that it is available on and through your TurnKey Account on the Site, Service. If there is information about your "friends" or people with whom you are associated in your Third Party Account, the information we obtain about those "friends" or people with whom you are associated, may also depend on the privacy settings such people have with the applicable SNS.
We also collect the other information that you provide as part of registration and the administration and personalization of your TurnKey Account profile (e.g., without limitation, zip code (on its own) and individual preferences or demographic information) ("Non-Identifying Information").
We use your Personal Information (in some cases, in conjunction with your Non-Identifying Information) mainly to provide the Service, complete your transactions, and administer your inquiries.
We also use your Personal Information to contact you with TurnKey newsletters, marketing or promotional materials and other information that may be of interest to you. If you decide at any time that you no longer wish to receive such communications from us, please follow the unsubscribe instructions provided in any of the communications or update your "Notifications" information. (See "Changing or Deleting Information," below.) Please note that we may also use your Personal Information to contact you with information related to your use of the Service; you may not opt out of these notifications.
When you visit the Sites, whether as a Member or a non-registered user just browsing (any of these, an "TurnKey User"), our servers automatically record information that your browser sends whenever you visit a website ("Log Data"). This Log Data may include information such as your computer's Internet Protocol ("IP") address, browser type or the webpage you were visiting before you came to our Sites, pages of our Sites that you visit, the time spent on those pages, information you search for on our Sites, access times and dates, and other statistics. We use this information to monitor and analyze use of the Site, Application and the Service and for the Sites technical administration, to increase our Site functionality and user-friendliness, and to better tailor our Sites to our visitors' needs. We also use this information to verify that visitors to the Site meet the criteria required to process their requests. We do not treat Log Data as Personal Information or use it in association with other Personal Information, though we may aggregate, analyze and evaluate such information for the same purposes as stated above regarding other Non-Identifying Information.
Our Sites may contain electronic images known as Web beacons (sometimes called single-pixel gifs) and are used along with cookies to compile aggregated statistics to analyze how our Sites are used and may be used in some of our emails to let us know which emails and links have been opened by recipients. This allows us to gauge the effectiveness of our customer communications and marketing campaigns.
Emailing Via an TurnKey Account
As part of the Service, TurnKey users may communicate with us via email or the "Contact Host" feature on the sites in which we advertise our listings (e.g., VRBO). Where users have selected the option of adding one or more email addresses to an online form, the message they create in the corresponding template will be sent to TurnKey from those email addresses via the advertising sites. These email addresses will be used by TurnKey only for the purpose of sending the email communication to the addressee. Via the "Contact Host" feature of the advertising sites, you may also speak with TurnKey representatives over the phone. These phone numbers will only be used by TurnKey to fulfill the Services.
Identity theft and the practice currently known as "phishing" are of great concern to TurnKey. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information, your TurnKey Account ID, login password, or national identification numbers in a non-secure or unsolicited e-mail or telephone communication. For more information about phishing, visit the Federal Trade Commission's website athttp://www.ftc.gov
Information Sharing and Disclosure
The Sites can be used to facilitate the listing and booking of rentals. Listings for such rentals are made available via the Sites by homeowners. Listings, ratings and reviews of rentals by guests are visible to any TurnKey user.
If you as a homeowner in our Service authorize TurnKey to post your rental listing, we may publish that listing publicly via the Sites and may enable third parties to publish your listing on their websites. We may also display the geographical location of your listing in the form of a map and street address.
If you request to make a booking via the Site, TurnKey may share the following information about you with the applicable homeowner: (i) your first and last name, email and phone number, (ii) the names of any members of an SNS with whom you are "friends" or associated on the SNS; and (iii) in certain cases your billing information.
Aggregate Information and Non-Identifying Information
We may share aggregated information that does not include Personal Information and we may otherwise disclose Non-Identifying Information and Log Data with third parties for industry analysis, demographic profiling and other purposes. Any aggregated information shared in these contexts will not contain your Personal Information.
Compliance with Laws and Law Enforcement; Guarantee Program
TurnKey cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of TurnKey or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, unethical or legally actionable activity.
We will disclose any information about you to government or law enforcement officials and to our insurance services providers as we, in our sole discretion, believe necessary or appropriate to administer our Services, to protect the property and rights of TurnKey or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, unethical or legally actionable activity.
TurnKey may sell, transfer or otherwise share some or all of its assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.
Changing or Deleting Your Information
All Members may review, update, correct or delete the Personal Information in their registration profile by contacting us atservice@TurnKeyVR.comor editing the relevant part of their profile. If you would like us to cancel your TurnKey Account, please contact us. Please note that, if you cancel your TurnKey Account, any reviews you have posted via the Sites will remain publicly viewable via the Sites. Please see below for privacy contact information.
TurnKey is very concerned with safeguarding your information. When you enter sensitive information (such as credit card number and/or social security number) on our registration or order forms, we encrypt that information using secure socket layer technology (SSL). We follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Sites, you can contact us.
We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored "personal data" (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting on the Sites in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
Links to Other Websites
Our Sites contain links to other websites. If you choose to visit an advertiser by "clicking on" a banner ad or other type of advertisement, or click on another third party link, you will be directed to that third party's website. The fact that we link to a website or present a banner ad or other type of advertisement is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other websites follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.
With your consent we may post your testimonial on the Sites along with your name. If you want your testimonial removed please contact us.
Our Policy Toward Children
The Sites are not directed to individuals under 18. We do not knowingly collect personally identifiable information from children under 13. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us. If we become aware that a child under 13 has provided us with Personal Information, we will delete such information from our files.