Protecting your privacy is nothing new for
us. We recognize that you want to understand how personally
identifiable data about you is being gathered and used. We
also recognize that you want to be able to make knowledgeable
choices about whether to limit the manner in which personally
identifiable data about you is used. This Privacy Policy is
our current policy on these subjects. To understand this Privacy
Policy, you should read the entire policy carefully.
PLEASE NOTE THAT BY USING THE WEB SITE YOU AGREE TO BE BOUND
BY THE TERMS AND CONDITIONS OF THIS POLICY, WHICH IS INCORPORATED
INTO AND SUBJECT TO THE TERMS OF OUR TERMS OF USE. IF AN INDIVIDUAL
IS USING THE WEB SITE ON BEHALF OF A BUSINESS ENTITY, WHETHER
AS AN EMPLOYEE, CONSULTANT OR AGENT OF SUCH BUSINESS ENTITY,
BY DOING SO, SUCH INDIVIDUAL REPRESENTS THAT THEY HAVE THE
LEGAL CAPACITY AND AUTHORITY TO BIND SUCH BUSINESS ENTITY
TO THIS PRIVACY POLICY. "YOU" SHALL REFER BOTH TO
THE INDIVIDUAL ACCESSING THE WEB SITE ON BEHALF OF A BUSINESS
ENTITY, IF ANY, AND ANY SUCH BUSINESS ENTITY ITSELF. IF YOU
DO NOT AGREE WITH THE TERMS AND CONDITIONS OF THIS PRIVACY
POLICY, PLEASE DO NOT USE THE WEB SITE.
When you read our Privacy Policy, you can expect to learn
about the following topics:
- Who We Are
- Scope and Nature of Policy
- Collection of Data
- Types and Sources of Data Gathered
- Use of "Cookies"
- Third Party Websites
- Retention of Data
- Data Security
- Use of Data
- Parties to Which We Disclose Data
- Type I Uses
- Type II Uses
- Sensitive Data
- Options to Limit Use of Data
- How to Access or Correct Data
- Future Changes in Policy
- Coordination with Applicable Law
- Information Regarding Former Customers
- Customer Questions
- What You Consent and Agree To
As used in this Privacy Policy, the terms “we”
and “us” mean Top VIP Limousine Service, Inc.
DBA Top VIP Transportation. We operate vehicles and provide
transportation services.
Because this Privacy Policy sets forth only our privacy practices,
it does not describe the privacy practices of our affiliates
(or, indeed, any other parties excluded from the definition
of “we” and “us”). In fact, our affiliates
have their own privacy policies, which may be different from
ours. To learn about the privacy practices of any of our affiliates,
you should review the privacy policies of such affiliates,
not this Privacy Policy.
If you have any question about whether a company is part
of us, or one of our affiliates, you may find out by contacting
us in the manner described below under the heading "Customer
Questions."
This Privacy Policy covers personally identifiable data collected
from and about you — individuals who are customers and
prospective customers of our businesses. "Personally
identifiable data" means any data about an identified
or identifiable individual that are recorded in any form.
This Privacy Policy does not cover personally identifiable
data that we collect from and about our employees. It also
does not cover personally identifiable data that are in public
domain.
This Privacy Policy includes examples of the types of information
we may collect and the kinds of companies to which we may
disclose information. These examples are illustrative and
should not be considered a complete inventory of our information
collection or sharing practices. Accordingly, the words "include"
and "including" mean inclusion without limitation.
We do not knowingly solicit personally identifiable data
from persons under the age of 13 years.
As used in this Privacy Policy, the words "company"
and "companies" mean any corporation(s), limited
liability company or companies, partnership(s) or other similar
entity or entities.
In the ordinary course of our business, we gather personally
identifiable data about you, including:
- Information you provide, such as your name, address(es),
employer(s), employee identification number(s), telephone
number(s), fax number(s), e-mail address(es), date and place
of birth, credit card information, and other membership
reward program information and affiliations with companies
or associations;
- Information about your transactions with us, our affiliates
or others, such as the locations, dates and times of your
pickup and return, your arrival airlines and flight numbers
and the charges you incur; and
- Information we receive from third parties on your behalf.
We gather personally identifiable data about you from a variety
of sources, including websites we operate, websites operated
by others through which you can make a reservation with us,
computerized reservations systems utilized by travel agents
to make reservations with us, telephone calls to our reservations
and assistance centers, and similar programs, service agreements
with us, other agreements with us, We also may gather personally
identifiable data about you from other companies with which
we maintain business relationships.
We and our agents may use cookies to track customers and
potential customers who visit our websites or receive our
html-formatted commercial electronic mail messages (“html
e-mail”), and to facilitate their use of services offered
on our websites or in connection with html e-mail. A “cookie”
is a set of data that a web server stores on your computer
that enables the server to recognize your computer. Cookies
enable websites to “remember” your entries as
you move from page to page, or when you revisit the site from
time to time using the same computer. When used in conjunction
with html e-mail, cookies help to “remember” your
responses to such e-mail. The data set that makes up a cookie
will typically not have any meaning to anyone other than the
party that placed the cookie. A cookie cannot retrieve other
data from your computer’s hard drive or pass on computer
viruses.
Two different types of cookies may be used in connection
with our websites:
“Session cookies” track the user’s progression
through our sites in a single visit. These cookies enable
us or our agents to remember things as the user progresses
from one page to another. With most Internet browsers, session
cookies are either deleted or rendered inaccessible to us
and our agents as soon as the user closes his or her browser.
“Persistent cookies” enable us or our agents
to remember a user at the user’s next visit. Persistent
cookies are neither automatically erased nor rendered inaccessible
upon closing the user’s browser, although persistent
cookies will typically “expire” after some number
of years. Upon expiration, such cookies may be deleted by
the user’s browser or rendered inaccessible to us
and our agents. (If you do not want these cookies to remain
on your computer, you can erase them through use of your
browser settings.)
Both session and persistent cookies may also be used in connection
with html e-mail sent by us and our agents.
Your browser or other software you install may permit you
to restrict the use of session cookies, persistent cookies
or all cookies. If you elect not to permit the use of session
cookies, you may not be able to use our websites or certain
features of our html e-mail messages. If you elect not to
permit the use of persistent cookies only, you may still enjoy
the full functionality of our websites and html e-mail; however,
if you do so, you will need to re-enter some data when starting
a new website session or opening (or re-opening) an html e-mail.
In addition, certain of our web pages and html e-mail messages
may incorporate “pixel tags”, “web beacons”
or other technologies (collectively, “pixel tags”)
that allow us or our agents to track the actions of users
of our websites and recipients of our e-mail communications.
Pixel tags are used to collect non-personally identifiable
data that, when aggregated with similar data collected from
other website users or e-mail recipients, helps us to determine
popular destinations, average rental prices, quote and conversion
rates, click-throughs and other information that can be used
to improve our service to our customers. Furthermore, our
online and e-mail advertising vendors may use pixel tags in
connection with our websites and e-mail communications to
help manage our online and e-mail advertising campaigns and
to strengthen the effectiveness of such campaigns. For example,
if a vendor has placed a unique cookie on your computer, pixel
tag technology enables the vendor to recognize that cookie
during your visit to one of our websites and to learn which
online Hertz advertisement, if any, brought you to the website.
We do not use, and we seek to prohibit our agents from using,
pixel tags to directly collect your name, e-mail address or
other personally identifiable data; however, we may link non-personally
identifiable data collected by us and our agents via pixel
tags or cookies to personally identifiable data about you
that we have previously collected.
Our websites and html e-mail may contain links to third party
websites, which may or may not be operated in conjunction
with our websites. We do not monitor or control the information
collected when you choose to "click through" links
to these websites. The treatment of user data by the operators
of third party websites may be different from ours. For details
regarding their treatment of personally identifiable data
about you, you will need to read their privacy policies or
contact them.
While we generally retain personally identifiable data about
you as long as we believe it will be useful to us, we do not
retain personally identifiable data about you longer than
the law of the country and state in which it is being retained
permits. Currently, the principal place in which we retain
personally identifiable data about you is the State of California,
U.S.A.
We maintain reasonable physical, electronic, and procedural
safeguards to protect personally identifiable data about you
from loss, misuse and unauthorized access, disclosure, alteration
and destruction. As part of those precautions, we seek to
protect personally identifiable data about you through technologies
designed to safeguard the data during its transmission. We
restrict access to personally identifiable data about you
to those employees we determine need to know that information
for us and our licensees to provide services to you. We also
have adopted a policy under which employee misuse of personally
identifiable data about you is treated as a serious offense
for which disciplinary action may be taken. You should, however,
be aware that there is no method of transmitting or storing
data that is completely secure. Although their physical characteristics
are different, postal mail, telephone calls, faxes and transmissions
over the Internet all present possibilities of loss, misrouting,
interception and misuse of the data being transmitted.
When we decide what data to seek from or communicate to you,
or how to seek or communicate it, we try to strike a reasonable
balance between the security of your data and your convenience.
We do this because we believe our customers attach value to
both. As a result, we sometimes use a method of communication
that is less secure than some of its less convenient alternatives.
An important example of this occurs in the case of e-mail.
When we send e-mail to you, we send it in an unencrypted form.
We do this because we believe that many of our customers do
not currently have the capability to receive encrypted e-mail.
As a consequence, though, if our unencrypted e-mail intended
for you were misrouted or intercepted, it could be read more
easily than encrypted e-mail. Because e-mail to and from us
is not encrypted, please do not include any information you
regard as confidential, in any e-mail you send us.
To protect personally identifiable data about you effectively,
we need your help. Do not disclose under any circumstances
your personal identification number (or “PIN”)
or password to anyone, and please exercise due care and common
sense in disclosing your membership number to others; we note
that third parties to whom you disclose your member number
will not be bound by this Privacy Policy, and could abuse
such information and compromise your account with us. In any
event, to the extent that you have a legitimate reason for
disclosing your membership number to a third party, you should
carefully review such third party’s privacy policy prior
to such disclosure to understand how that party will treat
the disclosed information. If you have reason to believe that
any account with us is no longer secure, you must immediately
notify us of the problem by emailing us at admin@topviptransportation.com.
- Currently we do not disclose any information to any third
parties, and we do not plan to do so in the foreseeable
future.
We may use personally identifiable data about you for a variety
of purposes as described in this section, including, but not
limited to, using personally identifiable data about you to
make and process your reservations, provide you with customer
assistance, prepare your account statements and maintain and
develop software. We may use affiliates and non-affiliated
parties to perform such services for us. We also may disclose
information in response to requests from law enforcement agencies
or government regulators. A more detailed description of the
above uses and all other “Type I Uses” appears
below.
Whenever we disclose personally identifiable data about you
to a third party for an initial use or a protective use (as
described in the relevant paragraphs immediately below), the
third party’s privacy policy, and not ours, will apply
to such third party’s subsequent retention and use (including
disclosure) of the data.
By making a reservation with us, you are consenting to the
use and disclosure of personally identifiable data about you
for Type I Uses. If you do not wish to consent to such use
and disclosure of personally identifiable data about you,
please do not make a reservation with us.
Initial Uses. We may initially use the personally
identifiable data that we collect from you to make your reservations
with us; to process your transactions with us; to provide
you with other enhanced services you request; and to bill
and collect amounts owed to us for our provide services. Accordingly,
if you seek to pay our charges by a debit, charge or credit
card, we may disclose personally identifiable data about you
to the company issuing the card and to other companies that
assist in processing the charges. Similarly, if you seek to
have your charges invoiced to a third party, we may disclose
personally identifiable data about you to that third party
and to any companies that assist the third party in processing
invoices. Further, if you participate in a frequent flyer
or other affinity or membership rewards program operated by
a third party and seek to receive a reward based on a transaction
with us, we may disclose personally identifiable data about
you to the program's operator, as well as to companies assisting
the operator in the operation of the program, to permit you
to receive your membership rewards. In addition, if you choose
to do business with us through, or with the assistance of,
a third party reservations system, travel agent or other intermediary,
we may disclose personally identifiable data about you to
the intermediary to make, modify or cancel a reservation made
by or with the assistance of the intermediary, to respond
to questions or comments made by the intermediary on your
behalf, to facilitate any other task that the intermediary
advises us that you intend for the intermediary to fulfill,
or that such an intermediary would, as a matter of industry
practice, typically fulfill, and to pay any commission or
other fee that we may owe to the intermediary.
Protective Uses. We may use and disclose
personally identifiable data about you as we reasonably believe
is necessary to protect our business; to comply with applicable
law; to protect the rights, privacy, safety or property of
you or others; and to permit us to pursue available remedies
or limit the damages that we may sustain. For example, if
you breach our agreement, personally identifiable data about
you may be used, disclosed to third parties or publicly disclosed
to the extent necessary to enforce the agreement and recover
any amounts owed. As another example, we may, to the fullest
extent the law allows, disclose personally identifiable data
about you to law enforcement agencies to assist them in identifying
individuals who have been or may be engaged in illegal activities.
Disclosure in Corporate Acquisitions and Sales.
As we develop our businesses, we may acquire or sell assets,
including ownership interests in companies, and companies
may acquire financial interests in us. In those transactions,
personally identifiable data about you may be among the transferred
business assets. We may disclose personally identifiable data
about you to any company in connection with a proposed or
actual sale, merger, transfer, or exchange of all or a portion
of a business or operating unit if you do business or have
done business with that business or operating unit, but only
if that company agrees to use the data prior to any acquisition
solely for the purpose of making its acquisition decision
and to observe the relevant provisions of our Privacy Policy
with respect to the data. In the event that personally identifiable
data about you is transferred to a company acquiring assets
from us, we will require that company to agree to observe
the relevant provisions of our Privacy Policy with respect
to personally identifiable data about you (including any choices
you have made under our Privacy Policy to limit the use of
your data).
Disclosure to Agents. We may disclose personally
identifiable data about you to any individual or company that
we retain to assist us in the conduct of our business, including
an individual or company that performs marketing services
on our behalf, but only if that individual or company agrees
to use the personally identifiable data about you solely for
the purposes of performing the tasks on behalf of, and under
the instruction of, us and to observe the relevant provisions
of our Privacy Policy with respect to the data.
Use of Data from Others. We may obtain personally
identifiable data about you from our affiliates and from other
companies with which we have business relationships, including
our business partners such as airlines and hotels. Such information
may be merged with or used to enhance personally identifiable
data that we have collected previously, as permitted by applicable
law and our Privacy Policy.
Disclosure to Affiliates. We may share personally
identifiable data about you among ourselves and disclose such
data to our affiliates to enable us to perform the functions
described above. In the event that personally identifiable
data about you is shared among ourselves or disclosed to our
affiliates, the party with which we share or to which we disclose
such data will be required to agree to observe the relevant
provisions of our Privacy Policy with respect to personally
identifiable data about you (including any choices you may
have made under our Privacy Policy to limit the use of your
data).
The uses of personally identifiable data about you described
under this heading are called "Type II Uses." Type
II Uses relate to uses of personally identifiable data about
you for marketing purposes. You have the right to "opt
out" of Type II Uses in the manner described below under
the heading Options to Limit Use of Data.
We may aggregate and analyze all of the personally identifiable
data about you to enable us to develop targeted marketing
programs and service offerings that we believe are tailored
to the needs of particular groups of customers. We may then
use the personally identifiable data about you to contact
you regarding programs and services (both our own programs
and services and third party programs and services) we believe
might be of interest to you. If you wish us not to contact
you for this purpose, you may choose Option A described below
under Options to Limit Use of Data.
We may share all of the personally identifiable data about
you among ourselves and disclose such data to our affiliates
and licensees for marketing purposes, provided the affiliates
to which we disclose the data agree to observe the relevant
provisions of our Privacy Policy with respect to the data
being disclosed (including any choices you have made under
our Privacy Policy to limit the use of your data). If you
wish us not to disclose personally identifiable data about
you to our affiliates for marketing purposes, you may choose
Option A described below under Options to Limit Use of Data.
We may also disclose all of the personally identifiable data
about you to companies that are not our affiliates for their
marketing purposes. When we disclose personally identifiable
data about you to companies that are not our affiliates for
their marketing purposes, we do not require those companies
to observe any particular policies with respect to their use
or disclosure of the data. They may treat privacy issues very
differently from the way we do. If you wish us not to disclose
personally identifiable data about you to companies that are
not our affiliates for their marketing purposes, you may choose
Option B described below under Options to Limit Use of Data.
Sometimes we may obtain data about your health conditions.
The most common way for this to occur is for you to ask us
to accommodate a disability. For example, you may request
that hand controls be installed on a vehicle, or that you
be brought to or from a location by accessible transportation.
We do not disclose data about your health conditions to our
affiliates or our business partners other than as authorized
by the Safe Harbor Principles and applicable law, and we do
not use data about your health conditions for marketing purposes.
In some countries and states, we are legally required to
treat other personally identifiable data about you as sensitive
and to employ additional safeguards when collecting and using
that data. We will observe those requirements. If a country
or state legally requires us to treat other personally identifiable
data about you as sensitive and not to collect, use or disclose
it without your consent, then by making a reservation
with us and providing that data to us, you are consenting
to the collection, use and disclosure of that data by us,
but only for Type I Uses. We do not disclose that
data to our affiliates or our business partners other than
as authorized by the applicable law, and we do not use that
data for marketing purposes. If you do not wish to consent
to the collection, use and disclosure of that data for Type
I Uses, then please do not provide that data to us; if under
our policies, a reservation or transaction cannot be made
without that data, please do not make a reservation with us.
Options and Their Effect. You may elect either
or both of the following options to limit the use of personally
identifiable data about you:
A. You may direct us not to communicate any marketing
offers or materials to you in the course of our businesses
and not to disclose personally identifiable data about you
collected in the course of our rental businesses to our
affiliates for marketing purposes. If you do this,
we will not, after your direction becomes effective, either
communicate any marketing offers or materials to you in
the course of our businesses or disclose personally identifiable
data about you collected in the course of our businesses
to our affiliates for marketing purposes. (We are not, however,
responsible for any subsequent use by affiliates of data
disclosed to them before your direction became effective.)
B. You may direct us not to disclose personally
identifiable data about you collected in the course of our
businesses to companies that are not our affiliates for
their marketing purposes. If you do this, we will
not, after your direction becomes effective, disclose personally
identifiable data about you collected in the course of our
businesses to those companies for marketing purposes. (We
are not, however, responsible for any subsequent use by
third parties of data disclosed to them before your direction
became effective.)
Please note that if you give the direction described in Option
A above, you may not receive offers and services that may
be of great interest to you,.
How to Choose an Option.
Please email us at: admin@topviptransportation.com
for choosing your privacy options.
We make reasonable efforts to ensure that the personally
identifiable data we have about you is as accurate, current
and complete as necessary for the purposes for which we use
that data.
You have a reasonable right to access and review personally
identifiable data about you collected by us. You may correct
factual errors in that data by sending a request to us that
credibly shows the error. You should contact our main office
at: admin@topviptransportation.com
We make our Privacy Policy available through a link on the
home page of our website www.topviptransportation.com.
We reserve the right to change our Privacy Policy in the future.
Subject to applicable laws, any changes to our Privacy Policy
will be effective upon posting of the revised Privacy Policy
on the Internet, accessible from a link appearing on the home
page of our website. If we make changes, we will revise the
"Last Updated" date on the top or cover page of
our Privacy Policy.
If we change our Privacy Policy in a way that is less protective
of your privacy, then the change will not apply to our use
of any personally identifiable data about you that was collected
by us before the change was made, unless we notify you and
provide you with the opportunity to direct us not to make
new uses of personally identifiable data about you.
We currently do business in California. Depending on where
you live and where and how you request services from us, our
collection and use of personally identifiable data about you
may be governed by federal and state laws of the United States
(including the Gramm-Leach-Bliley Act), the laws of other
countries or the Safe Harbor Principles. Where applicable,
we will comply with such laws and the Safe Harbor Principles
regarding our collection and use of personally identifiable
data about you and will limit any disclosures of data accordingly.
We do not disclose personally identifiable data about former
customers or customers with inactive accounts, and even if
we do, we would do so only in accordance with our Privacy
Policy.
We hope our Privacy Policy answers your questions about our
collection and use of personally identifiable data about you.
If it does not, or if you have questions about whether we
are observing our Privacy Policy, you can write to us at admin@topviptransportation.com
What You Consent and Agree To
By providing us with personally identifiable data
about yourself, you consent and agree to the following:
- You consent to the collection and use of personally
identifiable data about you as described in the Collection
of Data and Use of Data sections above, subject only to
any choices you have made as described under Options to
Limit Use of Data, and to your right to access and correct
data as described in How to Access or Correct Data above.
- You specifically consent to:
- The disclosure of personally identifiable data
about you to the sponsor of a counter discount program as
described under Use of Data – Type I Uses –
Disclosure to Counter Discount Program Sponsors;
- The disclosure of personally identifiable data
about you in connection with corporate acquisitions and
sales as described under Use of Data – Type I Uses
– Disclosure in Corporate Acquisitions and Sales;
and
- The collection and use of any sensitive data about
you for Type I Uses as described under Use of Data –
Sensitive Data.
- You acknowledge that you accept the risks described
under Data Security and agree to take the precautions to
assist us in protecting your data described under Data Security.
- You agree that we may make changes in our Privacy
Policy as described under Future Changes in Policy.
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