Effective Date: 03/16/2023
Information We Collect About You
Below is a list of several different types of personal information collected about you for various purposes to provide and improve our Services to you.
- Individual Identifiers. While using our Services, we may ask you to provide us with or otherwise obtain certain personal identifiers that can be used to contact or identify you. Such personal information may include, but is not limited to: your name, email address, mailing address, phone number, purchase history at our resort, and other information necessary to facilitate your stay at our resort, restaurant, or spa, that may identify or relate to you.
- Usage Data. We may also collect personal information on how you access and use our Services (“Usage Data”). This Usage Data helps us understand how users interact with our Website, and may include aggregate Website usage metrics such as total number of visitors, pages viewed, and usage patterns within the Website, the pages of our Services that you visit, the time and date of your visit, the time spent on those pages, social media clicks, Google Ads clicked, device information such as device settings, user preferences, and unique device identifiers, and other diagnostic data.We also use Google Analytics to help us understand how you and other users access and use our Website and other Services, in order to improve our Services and provide you and other users with a better experience.
- Social Media Information. We also collect information about those individuals who interact with our advertisements on Facebook, Twitter, TikTok, and Instagram. This includes individuals’ interests, birthdays, general geographical location, age, gender, and additional information publicly available on the individual’s Facebook or Instagram account.
- User Content. We may also collect user content you make available on your social media page or review platforms. This information may include pictures, videos, or reviews of the Mirabelle Inn property that you post on third party platforms.
Cookies & Tracking Data
We may use the following types of cookies:
- Mandatory Cookies: cookies required to activate the core functionality of the Website. These cookies are used to process information that helps us secure the Websites and activate their functionality and cannot be disabled;
- Functional and Analytical Cookies: cookies used to analyze activities on the Website in order to improve and optimize the way our Website works. An example of these cookies is cookies that track Website usage.
Your Cookie Choices
You are in control as to which cookies and other tracking technologies are collected by your browser or device. You may set your browser to block or refuse all cookies, to indicate when a cookie is being sent, or otherwise control what cookie your browser or mobile device accepts via your browser or mobile device settings. Additionally, you can choose to modify your settings and delete those cookies that are otherwise stored on your device at any time.
How We Collect Information
We collect and obtain your information in a few ways: there is information that you choose to give to us, information we obtain through your use of our Services and/or our Website, and information we obtain from third parties.
The specific information we collect depends on how you use our Website and/or our other Services. The following information describes the categories of personal information Mirabelle Inn may collect and the categories of sources from which that information may have been collected.
- Information You Give Us: At times, we may require you to provide certain information – including personal information – in order to use certain parts of our Website, fulfill your requests with us, or provide you with the Services you request from us. For instance, we may require you to provide your name, email address or username when you contact us with a question or comment, or form of payment when you book a stay at our resort utilizing the Website. Additionally, we may need you to provide certain personal information to use other portions of our Services. We will also collect any information that you choose to provide to us, such as any content related to customer service requests or emails concerning your use of our Services.
- Information We Obtain When You Use Our Services: As noted above, we collect certain information from you through your use of our Services, such as Usage Data. For instance, in using our Website, we may collect information about the device you use to log into, access, and use the Website.
- Information We Automatically Collect: We automatically receive and store certain types of personal information whenever you interact with us or our Website. This information includes your IP address, browser type, and pages you visit when you interact with our Website. Like many websites, we use tracking technologies such as cookies, web beacons and similar technologies to record your preferences, track the use of our Website, clicks on and to our Website, and clicks to third party hyperlinks on our Website. We may also use these technologies to monitor web traffic, improve the Website, understand how our users interact with the Website, and make the Website easier to use and more relevant.
- Information We Receive from Other Sources/Third Parties. We collect information about you from data aggregation and data analytics services like Google Analytics. Google Analytics is a digital analytics service offered by Google Inc. that tracks, measures and generates information about a website’s traffic, sales, and similar information, and which may be used for statistical and marketing research. Please see http://www.google.com/analytics for more information about Google Analytics. We may use other third party analytic services as well. Other examples of personal information we collect from third parties include: personal information captured in online forms.
How We Use Your Personal Information
Such uses include, but are not limited to:
- To fulfill information request and to receive information and materials from us, such as to provide customer support services and answer live chat inquiries.
- To provide and maintain our Services.
- To notify you about changes to our Services.
- To gather analysis or valuable information so that we can audit and improve our Services.
- To monitor the usage of our Services.
- To detect, prevent and address technical or security issues, including security incidents.
- To detect and protect against malicious, deceptive, fraudulent, or illegal activity.
- We may also use “automatically collected” information and “cookies” information to:
- personalize our Services, such as remembering your information so that you will not have to re-enter it during your visit or the next time you visit the Website;
- monitor and analyze our effectiveness and third party marketing activities;
- monitor aggregate usage metrics such as total number of visitors, pages viewed, etc.; and
- track your entries, submissions, and status in any promotions or other activities.
How We Share Your Information With Others
Mirabelle Inn may disclose your information in a number of ways in order to provide our Services to you. For example, we may provide your personal information to third party service providers who assist us to facilitate or provide certain Services in relation to our business and therefore process personal information on our behalf. These include:
- IT service companies that host our website or assist us in developing our Website;
- Reservation booking service providers, such as those for booking hotel, spa, and restaurant reservations;
- IT support service providers; and
- Other third party service providers, such as our cloud storage and software providers.
These third party service providers are authorized to use your personal information only as necessary to provide their services to us.
We may also disclose or share your information for the following purposes:
- To comply with a legal obligation;
- To protect and defend Mirabelle Inn’s rights or property;
- To prevent or investigate possible wrongdoing in connection with the Services;
- To protect the personal safety of users of the Services or the public;
- To protect against legal liability, and/or;
- When there is a good faith belief that such action is necessary to investigate or protect against harmful activities to our guests, visitors, associates, or property (including the Website), or to others (including Mirabelle Inn itself). This may include disclosures to law enforcement to investigate potential criminal activity or other civil violations.
Categories of Third Parties that Receive Personal Information from Mirabelle Inn
We share or otherwise disclose individuals’ personal information to the following categories of third parties:
- Service Providers: We employ third party service providers, companies, individuals, and agents to facilitate and help us provide our Services to you. Such Service Providers perform tasks or functions on our behalf, provide Services-related services, or assist us in analyzing how our Services are used or delivered. These third parties are granted access to your information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
- Our affiliates and subsidiaries: We may share your information with other companies within the Mirabelle Inn family.
- Law Enforcement or Other Lawful Authority: We may from time to time be required to provide information to law enforcement or other governmental authorities pursuant to a warrant, court order, or other lawful process.
Over the last 12 months, we have shared the following types of personal information:
|Category of Information||Examples of Information Shared or Disclosed||Categories of Recipients|
|Identifying Information||Real name, mailing address, email address, phone number, and other identifiers.||Our service providers, marketing providers, other Mirabelle Inn affiliated entities, and law enforcement or other government entities (where required by law)|
|Device Information||Mobile device, name, identifier and address; geolocation; and other information you make available to us.||Our service providers, marketing providers, other Mirabelle Inn affiliated entities, and law enforcement or other government authorities (where required by law)|
|Financial Information||Billing and payment information.||Our service providers, other Mirabelle Inn affiliated entities, and law enforcement or other government entities (where required by law)|
|Usage and Technical Information||Information about your interaction with our Website and content on third-party sites or platforms, such as social networking sites (e.g. IP address; browsing history; search history; device information; information about user’s interaction with Website, such as scrolling, clicks, and mouse-overs (via cookies, pixel tags, web beacons, transparent GIFs); browser information; operating system and platform; geolocation information; user content (e.g. photos, videos, audio, images, social media /online posts, first-party works).||Our service providers, and government entities (where required by law)|
Categories of Personal Information Sold
We do not sell your personal information to third parties. Please note that “sale” of personal information does not include those instances when such information is part of a merger, acquisition, or other transaction involving all or part of our business. If we sell all or part of our business, make a sale or transfer of assets, or are otherwise involved in a merger or other business transaction, we may transfer your personal information to a third party as part of that transaction. If such transaction materially affects the manner in which your personal information is processed, we will notify you of such change prior to its implementation.
How We Secure Your Personal Information
We take reasonable technical, organizational, physical, and other measures to protect your information from unauthorized or unlawful access, destruction, loss, alteration, or disclosure.
However, no website, network, or system can be absolutely protected against intentional or malicious intrusion attempts despite our precautions. Furthermore, Mirabelle Inn does not control the devices, computer or network through which you access the Website or over which you may choose to send personal information or other information to us, and therefore cannot prevent potential interceptions or compromises to your information while in transit. Mirabelle Inn makes no guarantee as to the security, integrity or confidentiality of any information transmitted to or from our Website. We are committed to safeguarding your information to the best of our ability but cannot guarantee the security of electronic communications or transmission made over the Internet.
We will not retain your personal data for a period longer than necessary to fulfill the purposes for which it was collected for, unless we have to keep it for legitimate business, tax or legal purposes.
Transfer of Data
Your information, including personal information, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. This information may be subject to access requests from governments, courts, law enforcement officials and national security authorities in the United States according to its laws. Subject to the applicable laws, we will use reasonable efforts to ensure that appropriate protections are in place to maintain protections on the personal information.
If you are located outside United States and choose to provide information to us, please note that we transfer the data, including personal information, to United States and process it there. If you are located in the European Union, you should be aware that U.S. data protection laws are not deemed to be as adequate as those in the European Union. If your personal information is being transferred outside the EEA, Mirabelle Inn is committed to taking the necessary steps to protect your personal information in accordance with this Policy and applicable law. Such necessary steps may include putting in place appropriate contractual safeguards and other supplemental measures to protect your personal information. Please contact us if you’d like more information about the safeguards applicable to your personal information. Your submission of such information represents your agreement to that transfer.
Opting out of Marketing Communications
Your personal information may be used to provide you with information regarding additional opportunities and information about our Services; and by using the Website or Services and providing us with your personal information, you consent to such use. However, in the case of electronic direct marketing, we will provide you with a method to opt-out of receiving further marketing materials or with a method to opt-in if required by law.
Opt-out mechanisms will normally be available on the relevant email, Website, or Service, but you may notify us at the address specified below under “Contact Us”. Requests to opt out of communications based on data controlled by third parties must be made through the third party. Notwithstanding the foregoing, there may be some jurisdictions requiring stricter opt-in versus opt-out mechanisms relating to these types of communications and we will comply with the applicable laws in such locations.
Links to Other Websites
We exercise no control over and assume no responsibility for the content, privacy policies or practices of any third party site or services.
Privacy Information for California Residents
Mirabelle Inn has policies and procedures in place to facilitate the exercise of privacy rights available to California residents. If you are a California resident, the California Consumer Privacy Act (“CCPA”) requires us to disclose the following information with respect to our collection, use, and disclosure of personal information.
- Subject to certain limitations, California residents have the following rights under California law:
- Right to Access: To have access to your personal information upon simple request – that is, you may receive a copy of such information upon receipt of a verifiable request, along with other information related to the collection or processing.
- Right to Disclosure of Direct Marketers: To have access upon simple request, and free of charge, the categories and names/addresses of third parties that have received personal information for direct marketing purposes.
- Right to Information About Collecting, Selling, Sharing, or Disclosing Personal Information: Upon receipt of a verifiable request, you may obtain a list of:
- The specific pieces of your personal information Mirabelle Inn holds;
- The categories of personal information collected about you, sold to third parties, or disclosed to third parties for business purposes;
- The categories of personal information sold within the last 12 months;
- The categories of sources from which personal information is collected;
- The business or commercial purpose for collecting or selling personal information; and
- The categories of third parties with whom personal information is shared, sold, or disclosed for a business purpose.
- Right to Opt-Out of the Sale of Personal Information: California residents have the right to opt-out of the sale of their personal information under certain circumstances. As noted elsewhere, we do not sell your personal information.
- Right to Deletion: To obtain the deletion of your personal information in the situations set forth by applicable data protection law and upon receipt of a verifiable request.
- Right to Non-Discrimination. As defined under relevant law, you have a right to non-discrimination in the Services or quality of Services you receive from us for exercising your rights.
Exercising Your Privacy Rights
California residents can exercise these rights as outlined in the “Submitting a Privacy Rights Request” section below.
Under California law a consumer can appoint an “authorized agent” to make certain verifiable requests upon their behalf, such as the right to know what information we collect about the consumer or to request deletion of the consumer’s information. An “authorized agent” may submit a request on behalf of a California resident who has authorized the agent to act on their behalf. Because the security and privacy of your information is paramount, we will ask that you identify such persons and directly confirm that such persons are authorized to act as your agent and exercise your applicable rights under California law in such situations. This may require us to contact you directly and alert you that an individual has claimed to be your agent and is attempting to access or delete your information. We will also independently verify your identity to ensure that an unauthorized person is not attempting to impersonate you and exercise your rights without authorization. We will not share your information or honor any other requests in those situations where you cannot or do not grant permission in writing for an identified authorized agent to act on your behalf, or where we cannot independently verify your identity.
Your California Privacy Rights Regarding Direct Marketing Information
California residents have the right to request information from a company regarding the manner in which it shares certain categories of personal information with third parties for their direct marketing purposes, in addition to the rights set forth above.
Under California law, you have the right to send us a request at the designated address listed below in the “Contact Us” section to receive the following information:
- The categories of information we disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year;
- The names and addresses of the third parties that received the information; and
- If the nature of the third party’s business cannot be determined from their name, examples of the products or services marketed.
To make such a request, please provide sufficient information for us to determine if this applies to you, and attest to the fact that you are a California resident. Please also provide a current California address for our response. You may make this request in writing to us at the address provided in the “Contact Us” Section. Any such request must include “California Privacy Rights Direct Marketing Information Request” in the first line of the description, and include your name, street address, city, state and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through the address provided for this purpose below.
Note that responsive information may be provided in a standardized format that is not specific to you.
Our Policy on “Do Not Track” Signals under the California Online Protection Act (”CalOPPA”)
We do not support Do Not Track. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. We may also track your behavior over time and across third party websites or other services. You can enable or disable “Do Not Track” by visiting the “Preferences” or “Settings” page of your web browser.
Third parties may collect data that relates to you via your use of our Website. We cannot control third parties’ responses to do-not-track signals or other such mechanisms. Third parties’ use of data relating to you and responsiveness to do-not-track signals is governed by their respective privacy policies.
Privacy Information for Residents of the European Union (“EU”) / European Economic Area (“EEA”) and the United Kingdom (“UK”)
Residents of the EU, EEA and UK are afforded certain rights under the GDPR and the UK General Data Protection Regulation (“UK GDPR”). Mirabelle Inn has policies and procedures in place to facilitate the exercise of privacy rights available to EU, EEA, and UK residents. If you are a resident of the EU, EEA, or the UK, the following information also applies to you.
Purposes of Processing and Legal Basis for Processing
As explained above, we process Personal Information in various ways depending upon your use of our Sites and Services. We process Personal Information on the following legal bases:
- with your consent;
- as necessary to perform a contract; and
- as necessary for our legitimate interests in providing the Sites and Services, where those interests do not override your fundamental rights and freedom related to data privacy.
Disclosures and Transfers
Personal Information we collect may be disclosed to third parties as described in the How We Share Your Information With Others section above or transferred to, and stored and processed in, the United States or any other country in which we or our affiliates or subcontractors maintain facilities. Transfers of Personal Information to a third country or an international organization are subject to appropriate safeguards as described in Article 46 of the General Data Protection Regulation (GDPR).
If you are a resident of the EEA or the UK, you are entitled to the following rights:
- Right to Access / Disclosure: The right to have access to your personal data upon simple request – that is, you may receive a copy of such data upon receipt of a verifiable request, along with other information related to the processing.
- Right to Correction/Rectification: The right to correct your personal data if you find it is inaccurate, incomplete or obsolete.
- Right to Erasure / “Right to be Forgotten”: The right to obtain the deletion of your personal data in the situations set forth by applicable data protection law.
- Withdrawal of Consent to Processing: The right to withdraw your consent to the data processing without affecting the lawfulness of processing, where your personal data has been collected and processed based on your consent and not any other basis.
- Right to Object: The right to object to the processing of your personal data under certain circumstances, in which case we may ask you to justify your request by explaining to us your particular situation.
- Right to Restrict Processing: The right to request limits to the processing of your data, when allowed by and in circumstances set forth under applicable law.
- Right to Restrict Automated Individual Decision-Making (Profiling): The right to not be subject to a decision based solely on automated processing, including profiling, that produces legal effects concerning you.
- Right to Data Portability: The right to have your personal data directly transferred by us to a third-party processor of your choice (where technically feasible; may be limited to situations when processing is based on your consent).
- Right to Complain to Data Protection Authority: The right to lodge a complaint about the way we handle or process your Personal Information with your national data protection authority.
To exercise any of these rights, please contact Mirabelle Inn as described in the “Submitting a Privacy Rights Request” section below. Note that we may ask you to verify your identity before responding to such requests.
Submitting a Privacy Rights Request
As described above, California, U.K., and EEA residents have certain rights with respect to the collection, use, transfer, and processing of your personal data, as defined by the CCPA, GDPR, and UK Data Protection Act. Please contact us utilizing the toll-free number or email address listed in the “Contact Us” section below in relation to exercising these rights.
We may ask you to provide information about yourself so that we can verify your identity as part of this process. This information may include your name, email address, account information, and any other information deemed necessary by us to reasonably verify your identity, to ensure that your information is not shared with anyone impersonating you. Once we have verified your identity, we will work to fulfill your request in a timely manner. Please note there may be some situations in which we are unable to fulfill your request, such as if we cannot find any information about you within our systems. Additionally, we may not be able to honor a deletion request in some situations, such as if your information is necessary to fulfill the Services you requested or meet a legal obligation. We will inform you whether we can fulfill your rights request.
We may ask for additional information if we have difficulty confirming your identity. We will not share your information or honor other requests in those situations in which we are unable to confirm a request for your information is a “verifiable request.”