Vacation Capital Group Management, Inc. d/b/a Villatel, and its subsidiaries and affiliates ("Homes by Villatel," "we," "our," or "us"), provide this Privacy Policy (this "Policy") to inform you of our policies and procedures regarding the collection, use, and disclosure of Personal Information we receive from users of www.homesbyvillatel.com (the "Site") and our other products and services (collectively, the "Services"). This Policy also describes your rights and choices regarding your Personal Information, and how you can contact us if you have questions or concerns. For purposes of this Policy, "Personal Information" means information that identifies, relates to, describes, or could reasonably be linked, directly or indirectly, with a particular individual or household.
1.Personal Information We Collect
We collect Personal Information from the sources described below. Where applicable, we indicate whether you are required to provide Personal Information and the consequences of not doing so. If you do not provide requested Personal Information, you may be unable to use some features of the Services. We collect Personal Information directly from you, automatically through your use of the Services, and from third parties.
1.1 Information You Provide
Registration and Account. When you register and create an account ("Account"), or become a customer ("Customer") by booking an accommodation ("Accommodation"), we collect information such as your name, contact details (phone number, email, and postal address), date of birth, booking information, and any other information you choose to provide. We also collect the username and password you create. We may ask you to provide a copy of your passport or other government-issued ID for identity verification. Your payment information (such as credit card and billing details) is collected by our third-party payment processor on our behalf; we may store a hashed (tokenized) version of your card number in connection with your booking.
Profile and Preferences. We may collect information you provide to personalize your account and stay (for example, age, gender, household details such as whether you are traveling with children, and service preferences such as housekeeping or other add-ons).
1.2 Information From Your Interactions With Us
Communications. When you contact us by email, phone, mail, chat, SMS, or otherwise, we receive your contact details, the contents of your message and any attachments, and any information you choose to provide. You may also provide reviews or respond to surveys.
Customer Service. When you contact us with questions or requests, we keep a record of the communication and how it was handled.
1.3 Information We Collect Automatically
Cookies and Analytics. When you use the Services, we and our partners collect information through automated means such as cookies, pixels/web beacons, and server logs (collectively, "Cookies"). This includes IP address, browser and device characteristics, device identifiers, operating system, language preferences, referring URLs, and information about your use of the Services. We use your IP address to derive your approximate (coarse) location. We work with analytics providers, such as Google Analytics, that use Cookies and similar technologies to analyze use of the Services and report on activity and trends.
Use of Accommodations. We automatically collect information about your use of an Accommodation (for example, whether you are a returning guest, feedback you provide, or issues during your stay). Where required by law, we collect such information only with your consent.
1.4 Information We Collect From Third Parties
Social Media. If you link your Account to a third-party social media account (for example, Facebook or X), we may receive information from that account as permitted by its terms and your settings.
Third-Party Booking Services. When you book through a partner (for example, Airbnb or Vrbo), we may receive your name, email, phone number, account information held by that partner, and your stay details.
Other Sources. We may receive additional information, such as demographic data, from data or marketing partners, and combine it with information we already have about you.
2.How We Use Personal Information
We use Personal Information to: operate, provide, maintain, and improve the Services, and respond to your requests, comments, and questions; personalize content and your experience, including recognizing you as a returning guest and honoring your preferences; send newsletters, marketing, and promotional materials about Homes by Villatel and our partners (where required by law, only with your consent); link and enrich your Account with third-party accounts you connect; facilitate transactions and process payments; carry out business purposes such as audits, security, fraud prevention, quality assurance, and compliance with law; and create de-identified or aggregated data, which we may use and disclose for any lawful purpose.
Legal Bases (EEA/UK/Switzerland). If you are located in the European Economic Area, United Kingdom, or Switzerland, we process Personal Information only where we have a valid legal basis: your consent (for example, for marketing or certain Cookies); performance of a contract (for example, to manage your Account and bookings); compliance with a legal obligation (for example, tax and accounting); or our legitimate interests (for example, product development, analytics, and improving the safety, security, and performance of the Services), where not overridden by your rights.
3.Cookies and Similar Technologies
We and third parties use the following categories of Cookies: Operational/Strictly Necessary Cookies required to make the Site available; Functional Cookies that remember your preferences; Analytical Cookies for website analytics (including Google Analytics and Google Tag Manager); and Advertising Cookies from advertising partners (such as Google Ads) used to show you relevant ads on third-party sites and apps. Where required by law, we obtain your consent before using non-essential Cookies, and you can manage your choices through the cookie preferences / "Do Not Sell or Share My Personal Information" link in our Site footer and through your browser settings. See "Your Rights and Choices" and "Your U.S. State Privacy Rights" below for more, including opting out of advertising Cookies and targeted advertising.
4.How We Share Personal Information
We may share Personal Information as follows: with our affiliates and subsidiaries, whose use is subject to this Policy; with service providers, vendors, contractors, and agents who perform functions on our behalf; with third-party booking services to manage a booking made through them; with property managers and owners, including guest names and dates of stay, for property and security purposes; with business partners that provide value-added services in connection with the Services; with advertising and analytics partners (as described above); in connection with a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets; to comply with law, legal process, or lawful requests, and to protect our rights, our users, and the public; and with your consent or at your direction.
We do not sell your Personal Information for monetary consideration. As described in "Your U.S. State Privacy Rights," our use of Advertising Cookies for cross-context behavioral advertising may be considered a "sale" or "sharing" under certain state laws, and you may opt out.
5.Your Rights and Choices
Marketing Opt-Out. You can opt out of marketing emails by using the unsubscribe link in any such email. You will continue to receive non-promotional, administrative messages (for example, booking confirmations).
Opt-Out Preference Signals (Global Privacy Control). Your browser or a browser extension may let you send a Global Privacy Control ("GPC") signal. Where required by law, we treat a GPC signal as a valid request to opt the associated browser or device out of "sales," "sharing," and targeted advertising.
Cookie Choices. Most browsers let you decline or delete Cookies, and you can manage non-essential Cookies through the preferences link in our Site footer. You can learn about Google Analytics and opt out using Google's tools, including the Google Analytics opt-out browser add-on.
EEA/UK/Switzerland Rights. If you are located in these regions, you may request access to or a copy of your Personal Information; request correction, deletion, or restriction; object to certain processing; exercise data portability; and withdraw consent at any time. You also have the right to lodge a complaint with your local supervisory authority.
6.Your U.S. State Privacy Rights
Depending on where you live, you may have rights under U.S. state privacy laws, including the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA/CPRA"), and comprehensive privacy laws in states such as Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, and others. This section describes those rights and how to exercise them. Terms such as "Personal Information," "sale," "share," and "sensitive" have the meanings given by applicable state law.
Categories of Personal Information
In the preceding 12 months, we have collected the following statutory categories of Personal Information:
| Category | Examples | Collected |
|---|---|---|
| Identifiers | Name, email, phone, postal address, IP address, device IDs, account username | Yes |
| Customer records (Cal. Civ. Code 1798.80(e)) | Contact and billing details, government-issued ID | Yes |
| Protected classifications | Age / date of birth, gender (as voluntarily provided) | Yes |
| Commercial information | Booking and reservation history, services purchased, preferences | Yes |
| Internet / network activity | Browsing and usage of the Site, interactions, referring URLs | Yes |
| Geolocation data | Approximate (coarse) location derived from IP address | Yes |
| Audio / electronic information | Customer-service communications and records, as applicable | As applicable |
| Inferences | Preferences and characteristics derived to personalize the Services | Yes |
| Sensitive Personal Information | Government-issued ID; account login credentials; precise geolocation only if you enable it | Yes (limited) |
| Professional / employment; education | Not collected from guests | No |
Sources, Purposes, and Disclosures. We collect Personal Information from the sources described in Section 1, use it for the purposes described in Section 2, and disclose it to the categories of recipients described in Section 4 for the business purposes described in this Policy.
Sensitive Personal Information. The sensitive Personal Information we collect is used solely to provide the Services you request, for security and fraud prevention, and for other purposes permitted by law that do not give rise to the right to limit. We do not use or disclose sensitive Personal Information to infer characteristics about you.
Sale and Sharing. We do not sell Personal Information for monetary consideration. We use Advertising Cookies and similar technologies that may disclose online identifiers and internet-activity information to advertising partners for cross-context behavioral (targeted) advertising, which certain laws treat as a "sale" or "share." You may opt out as described below. We do not knowingly sell or share the Personal Information of consumers under 16.
Your Rights. Subject to applicable law and exceptions, you may have the right to: (i) know and access the Personal Information we have collected about you; (ii) delete your Personal Information; (iii) correct inaccurate Personal Information; (iv) obtain a portable copy of your Personal Information; (v) opt out of the "sale" or "sharing" of Personal Information and of targeted advertising; (vi) limit the use and disclosure of sensitive Personal Information; and (vii) not receive discriminatory treatment for exercising your rights.
How to Exercise Your Rights. Submit a request by emailing privacy@homesbyvillatel.com or by using the "Do Not Sell or Share My Personal Information" / cookie preferences link in our Site footer. Because we operate the Services online, email is our designated request method. We will verify your request using information associated with your Account or booking, and may ask for additional information to confirm your identity. You may use an authorized agent to submit a request on your behalf, subject to verification of the agent's authority.
Appeals. If we deny your request, you may appeal by replying to our decision or emailing privacy@homesbyvillatel.com with the subject line "Privacy Appeal." We will respond within the time required by applicable law. If your appeal is denied, you may contact your state attorney general.
California "Shine the Light." California residents may request information about our disclosure of Personal Information to third parties for those third parties' direct marketing purposes. To make a request, email privacy@homesbyvillatel.com.
7.Children's Privacy
The Site is not directed to children under 13, and we do not knowingly collect Personal Information from children under 13. If you believe a child has provided us Personal Information, please contact us and we will take appropriate steps to delete it.
8.Links to Other Websites
The Services may contain links to, or display content from, third parties. We are not responsible for the privacy practices of third parties, and the inclusion of a link does not imply our endorsement.
9.Data Security
We use reasonable physical, organizational, and technical safeguards designed to protect Personal Information. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.
10.Data Retention
We retain Personal Information for as long as necessary to fulfill the purposes described in this Policy, unless a longer retention period is required or permitted by law (for example, for tax, accounting, or legal compliance).
11.International Data Transfers
We operate in multiple jurisdictions, and Personal Information may be transferred to and processed in the United States or other countries that may not provide the same level of data protection as your home jurisdiction. Where required, we use appropriate safeguards for such transfers. By using the Services, you understand that your information may be transferred as described in this Policy.
12.Changes to This Policy
We may update this Policy from time to time. The "Last Updated" date above indicates when this Policy was last revised. If we make material changes, we will provide notice through the Services or by other means as required by law. Your continued use of the Services after changes become effective constitutes acceptance of the revised Policy.
13. How to Contact Us
Unless otherwise stated, Vacation Capital Group Management, Inc. d/b/a Villatel is the entity responsible (the "controller") for the processing of your Personal Information. For privacy questions or to exercise your rights, contact us at:
- privacy@homesbyvillatel.com
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Vacation Capital Group Management, Inc. d/b/a Villatel
777 Arthur Godfrey Road, Suite 202
Miami Beach, FL 33140, United States