Last Update: February 3, 2020
Equity LifeStyle Properties, Inc. (hereinafter, the "Company", "ELS", "we", "us" or "our") and its affiliates, values you as our guest and recognizes that privacy is important to you. We are committed to treating your personal information with care and respect. Our policy is designed to provide transparency into our practices, including how we collect, use and disclose data. This Policy describes the privacy practices of the Company for data that we collect:
- through websites operated by us from which you are accessing this Policy, including ThousandTrails.com, RVontheGo.com and other websites owned or controlled by us (collectively, the "Websites");
- through the software applications made available by us for use on or through computers and mobile devices (the "Apps");
- through our social media pages that we control from which you are accessing this Policy (collectively, our "Social Media Pages");
- through HTML-formatted email messages that we send you that link to this Policy and through your communications with us; and
- when you visit or stay as a guest at one of our properties ("Properties"), or through other offline interactions (collectively, "Property Visits and Offline Interactions").
Collectively, we refer to the Websites, the Apps and our Social Media Pages, as the "Online Services" and, together with the Property Visits and Offline Interactions, the "Services." By using the Services, you agree to the terms and conditions of this Policy.
TABLE OF CONTENTS
- TYPES OF INFORMATION WE COLLECT
- HOW WE COLLECT YOUR INFORMATION
- USE OF PERSONAL DATA AND OTHER DATA
- DATA SECURITY
- WITH WHOM YOUR INFORMATION MAY BE SHARED
- CHOICES AVAILABLE TO YOU REGARDING COLLECTION, USE AND DISTRIBUTION OF YOUR INFORMATION
- CHILDREN'S PRIVACY
- UPDATES TO POLICY
- ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS
1. TYPES OF INFORMATION WE COLLECT
We collect two basic types of information: Personal Data (herein defined) and Other Data (herein defined). "Personal Data" is data that identify you as an individual or relate to an identifiable individual. We collect Personal Data about your and from you in various different ways when you interact with our Services, such as:
- Postal address,
- Telephone number,
- Email address,
- Credit and debit card number or other payment data,
- Financial information,
- Date of birth,
- Driver's license or other government-issued identification data,
- Prior guest stays or interactions, goods and services purchased, special service and amenity requests,
- Social media account ID, profile photo and other data publicly available,
- Data about family members and companions, such as names and ages of children,
- Images, video and audio data via: security cameras located in common areas, such as lodges, at our properties,
- Guest preferences, enquiries and comments and any other personalized data ("Personal Preferences"), such as your interests, activities, language, purchase choices, services and amenities of which you advise us or which we learn about during your visit.
If you submit any Personal Data about other people to us or our Service Providers (e.g., if you make a reservation for another individual), you represent that you have the authority to do so and you permit us to use the data in accordance with this Policy.
"Other Data" is data that generally does not reveal your specific identity or does not directly relate to an individual. To the extent Other Data reveals your specific identity or relate to an individual, we will treat Other Data as Personal Data. Other Data includes:
- Browser and device data
- App usage data
- Data collected through cookies, pixel tags and other technologies
- Demographic data and other data provided by you
- Aggregated data
2. HOW WE COLLECT YOUR INFORMATION
We collect Personal Data in a variety of ways:
- Online Services. We collect Personal Data when you make a reservation, purchase goods and services from our Websites or Apps, communicate with us, or otherwise connect with us or post to social media pages, or sign up for a newsletter or participate in a survey, contest or promotional offer.
- Property Visits and Offline Interactions. We collect Personal Data when you visit our Properties, or use amenities and services, such as restaurants, stores and activity centers. We also collect Personal Data when you attend promotional events that we host or in which we participate, or when you provide your Personal Data to facilitate an event.
- Customer Service. We collect Personal Data when you make a reservation over the phone, communicate with us by email or fax or contact customer service. These communications may be recorded for purposes of quality assurance and training.
We collect Other Data in a variety of ways:
We collect Other Data through a variety of technologies, such as cookies, Flash cookies, pixels, tags, and application program interfaces, including when you visit our Online Services or use our Online Services on third-party sites or platforms using one or more devices, whether or not you are logged in or registered.
- Your browser or device. We collect certain data through your browser or automatically through your device, such as your computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, internet browser type and version and the name and version of the Online Services (such as the Apps) you are using. We use this data to ensure that the Online Services function properly.
- Your use of the Apps. We collect certain data when you download and use an App, such as App usage data, the date and time the App on your device accesses our servers and what data and files have been downloaded to the App based on your device number.
Cookies are also placed by other third parties, such as companies that track, measure and analyze various aspects of our web site activity in order to help us customize and improve the web site experience for visitors to our Online Services, and to provide other third parties with information about visitors to our Online Services to help optimize their marketing efforts.
You have choices with respect to cookies. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject all cookies you will be unable to use those services of our Online Services that require registration in order to participate. These services include auto-fill in of the logon form, the ability to book reservations, and potentially other features of our sites. However, you can still use other features of our Online Services even if you do not accept cookies. Our Online Services may also collect IP addresses which can be used to correlate a cookie with your specific computer or device.
Please also note that you can opt out of our advertising service provider(s) and other companies' tracking cookies by visiting the Digital Advertising Alliance located at http://www.aboutads.info/choices/ or the Network Advertising Initiative located at http://www.networkadvertising.org/choices/.
- Pixel Tags and other similar technologies. We collect data from pixel tags (also known as web beacons and clear GIFs), which are used with some Online Services to, among other things, track the actions of users of the Online Services (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Online Services.
3. USE OF PERSONAL DATA AND OTHER DATA
The primary goal of collecting Personal Data and Other Data is to provide you, the user, with a customized and optimized experience and to assist you in communications and completing transactions with us. We use Personal Data and Other Data for our legitimate business interests and to manage our contractual relationship with you, including the following:
- Provide the Services you request. We use Personal Data and Other Data to provide Services you request, including:
- To facilitate reservations, payment, send administrative information, confirmations or pre-arrival messages, and to provide you with other information about the area and the property at which you are scheduled to visit.
- To complete your reservation and stay, for example, to process your payment, ensure that your site or rental is available and provide you with related customer service.
- Communicate with you about services and goods according to your Personal Preferences. We use Personal Data and Other Data to send you marketing communications and promotional offers, as well as periodic customer satisfaction, market research or quality assurance surveys.
- Sweepstakes, activities, events and promotions. We use Personal Data and Other Data to allow you to participate in sweepstakes, contests and other promotions and to administer these activities. Some of these activities have additional rules and may contain additional information about how we use and disclose your Personal Data. We suggest that you read any such rules carefully.
- Business Purposes. We use Personal Data and Other Data for data analysis, audits, security and fraud monitoring and prevention (including with the use of closed circuit television, card keys, and other security systems), developing new goods and services, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
We will use and disclose Personal Data as we believe to be necessary or appropriate: (a) to comply with applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including authorities outside your country of residence and to meet national security or law enforcement requirements; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect the rights, privacy, safety or property of the Company, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
We may use and disclose Other Data for any purpose, except where we are not allowed to under applicable law. In some instances, we may combine Other Data with Personal Data (such as combining your name with your location). If we do, we will treat the combined data as Personal Data as long as it is combined.
4. DATA SECURITY
We implement and maintain reasonable security, technical, administrative and physical measures in order to protect against the loss, misuse or alteration of information that we have collected from you. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify as explained in "Choices available to you regarding collection, use and distribution of your information" below.
5. WITH WHOM YOUR INFORMATION MAY BE SHARED
As a general rule, we will not disclose any of your personally identifiable information except as set forth below. We may share Personal Data with our affiliated or subsidiary companies in order to better serve you and to offer you worthwhile products and services. Unless you otherwise request, we may also share all of the other information we collect with our affiliates. You may request that we not share this other information with our affiliates by following the procedure explained in "Choices available to you regarding collection, use, and distribution of your information." We will implement your request within a reasonable time after we receive it. We may share your Personal Data as set forth below.
- With agents and contractors who help us run our Services or perform other services on our behalf (e.g., e-mail delivery, mailing list management, analysis, optimization services, etc.). These companies are only allowed to retain, use and disclose your information for the specific task they've been hired to do and are required to keep your information confidential and secure.
- For legal-related purposes (if necessary), including disclosures in connection with a lawsuit or legal investigation, court order, governmental inquiry, enforcement of legal rights (e.g., contract terms, intellectual property rights, etc.), fraud investigation, safety issue, or other similar matter.
- We may also disclose account information in special cases when we have reason to believe that disclosing this information is necessary to identify, contact, or bring legal action against someone who may be violating the this Policy or may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, users of our Online Services, or anyone else that could be harmed by such activities. We may disclose or access account information when we believe in good faith that the law requires it and for administrative and other purposes that we deem necessary to maintain, service, and improve our products and services.
- In connection therewith:
- If you supply us with your email address, you may receive periodic e-mails from us regarding products or services or upcoming events we think you might find interesting. In addition, from time to time, we make our e-mail list available to other reputable organizations whose products or services we think you might find interesting.
- If you supply us with your postal address, you may receive periodic mailings from us with information regarding products or services or upcoming events we think you might find interesting. In addition, from time to time, we make our customer mailing list available to other reputable organizations whose products or services we think you might find interesting.
- If you supply us with your telephone number, you may receive telephone contact from us with information on new products or services or upcoming events we think you might find interesting.
If you do not wish to receive such emails, mailings or telephone calls, please follow the procedure explained in "Choices available to you regarding collection, use and distribution of your information" below or "Additional Information for California Residents". We will implement your request within a reasonable time after we receive it.
6. CHOICES AVAILABLE TO YOU REGARDING COLLECTION, USE AND DISTRIBUTION OF YOUR INFORMATION
If you choose not to register or provide Personal Data, you can still use most of Services, but you will not be able to access areas or use features that require registration.
You may also contact us or tell us your preferences by:
- Sending an email to firstname.lastname@example.org.
- Calling us toll free at 877-570-2267.
- Writing us at Equity LifeStyle Properties, Inc., Two North Riverside Plaza, Suite 800, Chicago, IL 60606, Attn: Privacy
When you contact us, please be prepared to provide the following information for each individual:
- First name, middle initial and last name
- Address, city, state and ZIP code
- Telephone number (if applicable)
- E-mail address (if applicable)
7. CHILDREN'S PRIVACY
Our Online Services are general audience sites. Children should always ask a parent for permission before sending personal information to anyone online. We do not intentionally collect or share personal information about users under the age of 13. In addition, we will not send any direct email offers to users who indicate they are under the age of 13.
8. UPDATES TO POLICY
From time to time, we may change this Policy to accommodate new technologies, industry practices, regulatory requirements or for other purposes. The "Last Updated" legend at the top of this page indicates when this page was last revised. Any changes will become effective when we post the revised Policy. Your use of the Services following these changes means that you accept the revised Policy.
9. ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS
Over the past 12 months, we have collected and disclosed the following categories of personal information from or about you or your device:
- Identifiers, such as your name phone number, mailing address, email address, IP address, date of birth, driver's license or other government-issued identification data, social media account ID, and names of family members. This information is collected directly from you and your device.
- Internet or other electronic network activity information, such as your information browser and device data, app usage data, data collected through cookies, pixel tags, and other technologies. This information is collected directly from you and your device.
- Commercial information such as credit and debit card number or other payment data and financial information. This information is collected directly from you.
- Audio and visual information such as your social media profile picture and images, video, and audio data collected via security cameras located at our properties. This information is collected directly from your social media platforms and from your visits to our properties.
- Other information described in subdivision (e) of Section 1798.80, including information about your gender (collected in the consumer context). This is collected directly from you.
We collect your personal information for the following purposes:
- To provide you the services your request, including facilitating reservations and payment, and sending administrative information, confirmations or pre-arrival messages;
- To improve, enhance, and modify our services and to develop new goods and services;
- For security and verification purposes, including to protect the rights, privacy, safety or property of the Company, you or others;
- To address and remediate technical issues and bugs.
We disclose personal information to the following types of entities:
- Other companies within the ELS corporate group who process your personal information in order to operate the business;
- Other companies that provide services on our behalf who are prohibited by contract from retaining, using, or disclosing personal information for any purpose other than for providing the services to us;
- Regulators and judicial authorities and law enforcement agencies;
- Entities that acquire all or substantially all of our business.
SALES OF PERSONAL INFORMATION
We have also shared your name, email address, and address with marketing partners so that they can send you information that may be of interest to you. To opt-out of this sharing of your personal information for these purposes, you can click here: Do Not Sell My Information.
Rights under the CCPA
If you are a California resident, you have the right to:
- Request we disclose to you free of charge the following information covering the 12 months preceding your request:
- the categories of personal information about you that we collected;
- the categories of sources from which the personal information was collected;
- the purpose for collecting personal information about you;
- the categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed (if applicable) and the purpose for disclosing the personal information about you; and
- the specific pieces of personal information we collected about you;
- Request we delete personal information we collected from you, unless California Consumer Privacy Act (CCPA) recognizes an exception; and
- Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or deny goods or services to you when you exercise your rights under the CCPA.
We aim to fulfill all verified requests within 45 days pursuant to the CCPA. If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay.
How to Exercise Your Rights
If you are a California resident to whom the CCPA applies, you may exercise your rights, if any, to other data by contacting us in writing by clicking here or contacting us at (888) 401-2272.
USE OF IMAGES
All images and/or pictures of properties featured on our Online Services are our property, and any unauthorized reproduction, appropriation, or distribution of the aforementioned images and/or pictures is prohibited.
WHAT YOU SHOUL KNOW BEFORE UPLOADING YOUR OWN CONTENT
If you upload your own content to our Online Services, such as comments, reviews, photos, or videos of your stay at one of our properties, you should note that this content will be accessible by the public at large, and not just by us. Therefore, you should never upload any content that you do not want others to have access to. It is also important that you only upload content that is not identifiable to you personally, such as your email or postal addresses, phone number, names of your children, etc. You should not upload photos of videos that include people that you do not know and/or have their permission to use.
EU GENERAL DATA PROTECTION REGULATIONS (GDPR) NOTICE
ThousandTrails.com does not envisage the offering of its products and services to individuals located in the European Union.
Les produits et services offerts sur ThousandTrails.com ne s'adressent pas aux particuliers situés dans l'Union européenne.
ThousandTrails.com no planea ofrecer sus productos y servicios a individuos que viven en la Unión Europea.
The Company and/or its affiliates and suppliers make no representations about the suitability of the information, products, software and services contained on this website. Information contained on this website is provided "as is" without warranty of any kind. The Company and/or its respective affiliates and suppliers hereby disclaim all warranties with regard to this information, software, products, and services, including all implied warranties of merchantability, fitness for a particular purpose, title and non-infringement. In no event shall the Company and/or its suppliers be liable for any direct, indirect, punitive, incidental, special or consequential damages arising out of or in any way connected with the use of this website or with any delay in using or inability to use this website, or for any information, software, products, or services obtained through this website, or otherwise arising out of the use of this website, whether based on contract, tort, strict liability or otherwise, even if the Company or any of its suppliers has been advised of the possibility of such damages. Because some states/jurisdictions do not allow the exclusion or limitation of liability for consequential or incidental damages, the above limitation may not apply to you. Reservations based on inaccurate information are subject to cancellation at our discretion.
DIGITAL MILLENNIUM COPYRIGHT ACT ("DMCA") NOTICE
If you believe any material available via this website infringes a copyright you own or control, you may file a notification of such infringement with our Designated Agent as set forth below.
Equity LifeStyle Properties, Inc.
Two North Riverside Plaza, Suite 800
Chicago, IL 60606
Attention: DMCA Designated Agent
Please see 17 U.S.C. §512(c)(3) for the requirements of a proper notification. You should note that if you knowingly misrepresent in your notification that the material or activity is infringing, you will be liable for any damages, including costs and attorneys' fees, incurred by us or the alleged infringer as the result of our relying upon such misrepresentation in removing or disabling access to the material or activity claimed to be infringing.
If a notice of copyright infringement has been filed against material posted by you on the website, you may make a counter-notification with our Designated Agent listed above, provided that such counter-notification complies with the requirements of 17 U.S.C. §512(g)(3). If we receive a valid counter-notification, it may reinstate the removed or disabled material in accordance with the DMCA.