Collection of Your Personal Information
“Personal Information” refers to information that relates to an identified, or identifiable, person. This includes, for example, your first and last name, home address or email address. In addition to Personal Information, we also collect “non-personal information,” which is information that does not identify you. Examples of non-personal information include age range and gender, or aggregate information. The Personal Information that we collect depends on what services you use or information that you request. Our collection and processing of your information is based on different contexts: our performance of a contract, our obligations under law, our legitimate interest in conducting our business, protection of a natural person’s vital interests and/or upon your consent. The following are examples of some Personal Information that we may collect as well as when and how we collect it.
Registration and Transactional Data
When you register on or use our Website, we may collect various kinds of Personal Information, including your first and last name, email address, home address, home phone number, personal interests and preferred vacation/leisure destinations. The information is used to process your requests or to send you information about the Company, our products, services or offerings.
From time to time, we may post surveys on our Website or otherwise send you surveys. The surveys may request demographic information (such as age range, gender, areas of interest and familiarity with Company or our products and services) and customer feedback. Participation in these requests is completely voluntary. With each request, you will have the choice of whether or not to disclose information. Such survey information will be used to improve our products and services and the overall experience on our Website.
Customer Service Correspondence
We may collect information that identifies you individually, such as your first and last name, home address, email address, phone number, and fax number when you submit comments, questions or suggestions to our customer service department. We use that information to verify your identity and to respond to your correspondence.
We may use information about you for statistical, design or operational purposes such as to estimate our audience size, to measure aggregate traffic patterns and/or to understand demographics, customer interest, purchasing and other trends among our users and customers, including you.
Marketing and Promotions
We may also use your Personal Information for the marketing and/or promotion of Company, our subsidiaries and/or affiliated companies, including their products and services.
Sharing Your Personal Information
We may share your information with service providers and others who help us operate our business or provide services on our behalf.
We may share your information with companies that are under common or shared ownership or control with Company, our subsidiaries and/or affiliated companies.
We may share or sell your information as an asset of Company in conjunction with the sale to a third party of our Company, our subsidiaries and/or affiliated companies, or a portion of our or their assets.
We may share your information:
to conform with the law, respond to claims or comply with legal process served on Company (e.g., a lawful subpoena, warrant or court order, or discovery request);
to enforce or apply our policies or agreements (including to bill and collect for amounts owed to us);
to protect and defend our or our users’ rights or property, our Websites, our employees, users, or the public, including fraudulent, abusive or unlawful use of our Website; or
if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires disclosure of communications or justifies disclosure of records without delay.
You can make the following choices regarding your Personal Information:
Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in emails that you receive or by contacting us with such request pursuant to the “How to Contact Us” section below. If you decide not to receive promotional emails, we may still send you service-related communications.
Promotional Mailings. If at any time you do not want to receive offers and/or circulars from us, you can remove yourself from our mailing list by contacting us with such request pursuant to the “How to Contact Us” section below and including “NO U.S. MAIL” in the subject line along with your name, address and zip code. Although we will remove your name from our mailing list after receiving your request, you may still receive mailings from us that had been initiated prior to your name being removed.
Promotional Text Messages. If you receive a text message from us that contains promotional information, you can opt out of receiving future text messages by replying “STOP” or otherwise contacting us with such request pursuant to the “How to Contact Us” section below.
Changes to Your Personal Information. We rely on you to update and correct your Personal Information. Note that we may keep historical information in our backup files as permitted by law. If our Website does not permit you to update or correct certain information, contact us with such request pursuant to the “How to Contact Us” section below.
Revocation of Consent. You may revoke consent, or object, to specific processing of your Personal Information by contacting us with such request pursuant to the “How to Contact Us” section below. If you revoke your consent for the processing of Personal Information, then we may no longer be able to provide you services. In some cases, we may limit or deny your request to revoke consent if the law permits or requires us to do so, or if we are unable to adequately verify your identity.
Access to Your Personal Information. If required by law, upon request, we will grant you reasonable access to the Personal Information that we have about you. You may request access to your Personal Information by contacting us with such request pursuant to the “How to Contact Us” section below.
Online Tracking. We do not currently recognize automated browser signals regarding tracking mechanisms, which may include “Do Not Track” instructions.
California Residents. California residents may be entitled to ask us for a notice describing what categories of Personal Information (if any) we share with third parties or affiliates for direct marketing purposes. If you are a California resident and would like a copy of such notice, please submit a written request to us pursuant to the “How to Contact Us” section below.
Protecting Your Information
To help maintain data accuracy, prevent unauthorized access to or disclosure of, and ensure the appropriate use of your Personal Information, we have put in place physical, electronic and managerial procedures. In the event that we are required by law to inform you of any unauthorized access to your Personal Information, we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
Retention of Information
We retain Personal Information for the period necessary to fulfill the purposes outlined in this policy, or until an individual requests that we delete information about them, unless a longer retention period is required or is permitted by law. If you would like additional information concerning how long we keep a specific type of information, you can contact us pursuant to the “How to Contact Us” section below.
We collect aggregate information about you and your use of our Website whenever you visit us online. For instance, we may collect various forms of “click stream” information such as entry and exit points for our Website (i.e., referring URLs or domains), site traffic statistics, page views, impressions, and operating system and browser type. In addition, when you request pages on our Website, our servers automatically log your IP addresses. An IP address is a number that is automatically assigned to your computer whenever you are surfing the internet.
We also use third-party software that tracks traffic directed to the Website from affiliate websites and the purchases that result from this traffic. This information is aggregated and is not tied to an individual purchase.
This aggregate information generally will not identify you or be correlated to you individually for external purposes. We may collect, compile, store, publish, promote, report, sell, or otherwise disclose or use any and all aggregate information, provided that such information does not reveal your identity. When we share such information with other companies, and it is not traceable to any particular user. If we do correlate any aggregate information to you, such information will be treated like any other Personal Information under this policy.
Links to Other Sites
Third Party Tracking
We participate in behavior-based advertising. This means that a third party may use technology (e.g., cookies) to collect information about your use of our Website so that it can provide advertising about products and services tailored to your interests. That advertising may appear either on our Website, or on other websites. You can opt out of receiving advertising based on your browsing behavior from some network advertising companies by going to the Network Advertising Initiative and the Digital Advertising Alliance websites, although to completely prevent advertising based upon your browsing behavior you should also disable the cookies on your browser.
How to Contact Us
ELLICOTT DEVELOPMENT COMPANY
295 Main Street, Suite 210
Buffalo, New York 14203
Effective: January 2019