VacayMyWay - Vacation rentals, simplified. A refreshing new way to Vacay.

At VacayMyWay, integrity, trust and transparency are core principles of our company. We recognize that your privacy is particularly important, and we take it seriously. Please read this Privacy Statement carefully as it explains who we are, how and why we collect, store, use, and share your personal information. It also explains your rights in relation to your personal information and how to contact us.

IMPORTANT: BY USING OUR WEBSITE, MOBILE APPLICATION, AND/OR SERVICES AVAILABLE ON THE WEBSITE OR MOBILE APPLICATION, YOU GIVE YOUR CONSENT THAT ALL PERSONAL DATA THAT YOU SUBMIT MAY BE PROCESSED BY US IN THE MANNER AND FOR THE PURPOSES DESCRIBED BELOW. IF YOU DO NOT AGREE TO THESE TERMS AND CONDITIONS, DO NOT USE VACAYMYWAY.

1. Overview

Vaycaymyway, Inc. d/b/a VacayMyWay, a Delaware Corporation (“we”, “us”, “our”) collects, uses and is responsible for certain personal information about you. When we do so, we are subject to various laws in the United States depending on where you reside and the General Data Protection Regulation (“GDPR”) if you reside in the European Union (including in the United Kingdom).

When you create an account on VacayMyWay, list a property, make a booking, or sign up to receive information and special offers, you provide us your personal information. We also use automated technology like cookies to collect your information when you visit our website or use our mobile application. We may also receive your information from our business partners and other third parties to help us improve VacayMyWay and our services.

Your personal information may be used or shared to assist you in making a booking, provide assistance during your stay, communicate with you (including communications with property owners and property managers through the platform), or our compliance with laws and regulations that apply to VacayMyWay.

2. Personal Information We Collect About You

When you use our platform, mobile application, or our services, we may collect and use the following kinds of personal information that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

Categories of Personal Information	Specific Types of Personal Information Collected
Identifiers	Real name, alias, home, business and billing addresses, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, tax identification number, driver’s license number, passport number, or other similar identifiers. Loyalty program and membership information.
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual.	Name, signature, social security number, physical characteristics or description, birth date, gender, address, telephone number, passport number, driver’s license or state identification card number as required for bookings or to verify identity, insurance policy number, bank account number, credit card number, debit card number, or any other financial information like expiration date and billing address. Images, videos, and other recordings. Social media account IDs and login information. Communications with us. Other communications that occur through our platform among partners, owners, and travelers. Any data that you provide us about other people such as travel companions.
Commercial information.	Real property records to verify ownership. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Internet or other electronic network activity information.	Browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement including pages accessed, links clicked, trips viewed, features used, and the corresponding date and time. IP address, device type, unique device identification number, internet browser type, internet service provider, operating system, mobile carrier,
Geolocation data	General geographic location data such as country, state, and city level information.
Mobile Application data	Device connectivity information such as carrier, network, operator, SIM operator, and SIM country. Operating system, operating version, and device model. Performance and data usage. Device settings selected or enabled such as Wi-Fi, GPS, and Bluetooth. Device settings. Usage data concerning your interaction with our mobile application.
Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Travel related preferences such as accessibility requirements, destinations, price point, type of accommodation, dietary needs, and wish lists

This personal information is required to provide services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing services to you.

3. How Your Personal Information is Collected

We collect most of this personal information directly from you: in person, by telephone, text, email, and/or via our website and apps. However, we may also collect information:

From publicly accessible sources (e.g., property records);
Directly from a third party (e.g., our partners, insurance agencies, credit reporting agencies, or customer due diligence providers);
From a third party with your consent (e.g., your bank);
From cookies on our website; and
Via our IT systems, including automated monitoring of our website, mobile application, and other technical systems, such as our computer networks and connections, access control systems, communications systems, and email and instant messaging systems.

Our Cookie Statement expands upon how we use cookies and other similar tracking technologies.

Permissions for Location Based Services: Depending on your mobile device’s settings and permissions and your choice in whether to participate in certain services and programs offered by VacayMyWay, we may collect the location of your device by using GPS signals, cell phone towers, Wi-Fi signals, Bluetooth or other technologies. We will collect this information to enable certain location-based services available within the mobile application. To disable location capabilities of the app, you can log off or change your mobile device’s settings to turn off location-based services.

4. How and Why We Use Your Personal Information

Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:

To comply with our legal and regulatory obligations;
For the performance of our services for you or to take steps at your request before providing the services;
For our legitimate interests or those of a third party; or
Where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use your personal information for and our reasons for doing so:

What we use your personal information for	Our reasons
To provide the website, mobile application, and services to you.	To enable and process your property booking. To provide services related to your account or a booking. To create and update your account. To maintain your search and travel history, preferences, and similar information about your use of VacayMyWay. To facilitate processing of payments and related transactions. To administer loyalty and reward programs. To facilitate property and user reviews. To allow you to use VacayMyWay faster by using third-party sign-in functionality.
Communications and marketing.	To respond to your inquiries and information requests. To process your information choices. To facilitate communications between travelers and owners, property managers, and suppliers such as insurance providers. To contact you to provide booking confirmations, updates, for marketing purposes and for other purposes that are described in this Privacy Statement. To market VacayMyWay and our services, optimize our marketing to make it more relevant to you, and to analyze the effectiveness of our marketing. To administer promotions.
To prevent and detect fraud and unauthorized activities against you or VacayMyWay.	For our legitimate interests or those of a third party, i.e. to minimize fraud that could be damaging for us and for you.
Conducting checks to identify our customers and verify their identity.	To promote security and to comply with our legal and regulatory obligations.
Compliance.	To comply with all laws applicable to our business, protect our and our users’ rights, defend ourselves, and respond to legal process by law enforcement and other agencies that are part of the legal process. To comply with applicable security and anti-terrorism, anti-bribery, customs, immigration, and related due-diligence requirements.
Ensuring business policies are adhered to, e.g. policies covering security and internet use	For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you. To defend against claims and other liabilities. To manage other risks.
Operational reasons, such as improving efficiency, training, quality control, and dispute resolution.	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information	For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information. To comply with our legal and regulatory obligations.
Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures.	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price.
Preventing unauthorized access and modifications to systems	For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you. To comply with our legal and regulatory obligations.
Updating and enhancing customer records.	For the performance of our services through the platform or to take steps at your request before facilitating a booking. To comply with our legal and regulatory obligations. For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products.
Statutory returns.	To comply with our legal and regulatory obligations.
Ensuring safe working practices, staff administration and assessments.	To comply with our legal and regulatory obligations. For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you.
Marketing our services and those of selected third parties to existing and former customers; third parties who have previously expressed an interest in our services; and third parties with whom we have had no previous dealings.	For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers.
Credit reference checks via external credit reference agencies	For our legitimate interests or those of a third party, i.e. to ensure our customers are likely to be able to pay for our services, booking, and any property damage.
External audits, quality checks, and the audit of our accounts	For our legitimate interests or those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards. To comply with our legal and regulatory obligations
To operate our business as permitted by law.	For our legitimate interests. To create aggregated or otherwise anonymized or de-identified data for use and disclosure without restriction, where permissible.

The above table does not apply to special category personal information, which we will only process with your explicit consent.

5. Promotional Communications

We may use your personal information to send you updates (by email, text message, telephone, or mail) about VacayMyWay’s services, including exclusive offers, promotions or new products and services.

We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect and never sell it to other organizations outside of VacayMyWay for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by:

Contacting us at info@vacaymyway.com; or
Using the “unsubscribe” link in emails or “STOP” number in texts.

We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

As described in this Privacy Statement and where permitted by law, we routinely share personal information with:

Our affiliates, including companies within the VacayMyWay group. We share your personal information with companies within the VacayMyWay group. They may access, use, and share your personal information as described in this Privacy Statement.
Service providers. We share your personal information with third-party service providers that we use to help deliver our services to you and to operate our business. This includes, by way of example, payment service providers, customer service representatives, business analytics services, website hosts, compliance and fraud prevention services, marketing and targeted advertising services, credit reporting services, and our financial institutions. We require that third-party service providers protect personal information shared with them. Additionally, third-party service providers are prohibited from using directly identifying personal information for any purpose other than providing the services that we contracted with them to provide.
Travel-Related services providers. We share your personal information with travel-related service providers who assist in the facilitation of your booking. These include property owners, property managers, insurance brokers, and where available, activity providers. Travel-related service providers may contact you directly for additional information where required to facilitate your booking or to otherwise provide their services.
Third parties approved by you. We share your personal information with third parties that you have approved. This includes third-party payment providers and social media sites you choose to link your account to and use as a single sign-on to login to VacayMyWay using your social media credentials. While using single sign-on, you will share information with the social media company, or other provider (such as Google), information such as the fact that you have visited and interacted with VacayMyWay. These third parties may combine the information provided with other information that they already have about you. All information shared with these third parties shall be governed by their own privacy policy and they can inform you how to modify your privacy settings on their platforms.
Business Partners. We will share your information to third party business partners if we offer a service or product in conjunction with a business partner. Your information will be provided to the business partner for the purpose of assisting with marketing or providing the service or product. In most cases, the special offer or program will be presented in the name of the business partner, either individually or combined with VacayMyWay. You may also be redirected from VacayMyWay to the website of the business partner with notice.
Legal and Regulatory Obligations. We may disclose your personal information to enforce our contractual rights, contracts, and policies, or where we are otherwise required to do so by applicable law. This may arise in connection with responding to a request by law enforcement or other governmental authority in connection with actual or proposed litigation or regulatory actions. It may also arise where necessary, in our good faith opinion, to protect and defend our property, people, or other rights and interests. We may also disclose your personal information in response to a valid subpoena or other legal request or where required to remit taxes in the course of processing bookings and payments.
Our Corporate Transactions. We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a restructuring, divestiture, asset sale, or merger. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
Payment Processing. We use Stripe for payment, analytics, and other business services. Stripe collects identifying information about the devices that connect to its services. Stripe uses this information to operate and improve the services it provides to us, including for fraud detection. You can learn more about Stripe and read its privacy policy at https://stripe.com/privacy.

7. Personal Information We Sold or Disclosed for a Business Purpose

We have not sold to a third party any personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

In the preceding 12 months, we have disclosed for a business purpose to one or more third parties the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers);
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information;
Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);
Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement);
Geolocation data; and
Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

8. Where Your Personal Information is Held

The personal information that we process may be held at our offices and those of our VacayMyWay third party agencies, service providers, representatives and agents as described above (see above: “Who We Share Your Personal Information with”). The personal information may be transferred or transmitted to countries other that the country in which you reside. Those countries may have laws that treat data protection differently that the laws of your country

The servers for VacayMyWay’s platform are located within the United States. Some of the third parties that we share personal information with, in accordance with the terms of this Privacy Statement, may be based outside of the United States and will process your information in the country where they are based.

We have taken reasonable and appropriate steps to enact safeguards to ensure that your personal information will remain protected in accordance with the terms of this Privacy Statement. For instance, VacayMyWay has certified to the EU-U.S. and Swiss-U.S. Privacy Shield frameworks and adheres to the Privacy Shield Principals of Notice, Choice, Accountability for Onward Transfers, Security, Data Integrity and Purpose Limitation, Access, Recourse, Enforcement, and liability for personal information from the EU, Switzerland, and the United Kingdom. For more information about the Privacy Shield principals, please visit: www.privacyshield.gov. Additionally, we require that all third-party service providers to whom we transfer data have enacted appropriate safeguards in compliance with applicable data protection laws.

9. How Long Your Personal Information Will Be Kept

We will keep your personal information while you have an account with us or while we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:

To respond to any questions, complaints or claims made by you or on your behalf
To show that we treated you fairly;
To fulfill the purposes set forth in this Privacy Statement; or
To keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information. We will de-identify, aggregate, or anonymize your personal information if we intend to use it for analytical purposes over a longer period of time. When it is no longer necessary to retain your personal information, we will delete or anonymize it.

If you reside in the European Union or the United Kingdom, you have the following rights under the GDPR:

Right	Description
Right to Access	The right to be provided with a copy of your personal information (the right of access)
Right to Rectification	The right to require us to correct any mistakes in your personal information
Right to be Forgotten	The right to require us to delete your personal information—in certain situations
Right to Restriction of Processing	The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data
Right to Data Portability	The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
Right to Object	The right to object: i) at any time to your personal information being processed for direct marketing (including profiling); ii) in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.
Right Not to be Subject to Automated Individual Decision-Making	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner's Office (ICO) on individual rights under the General Data Protection Regulation.

11. Your Rights Under the CCPA

You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:

Item	Description
Disclosure of Personal Information We Collect About You	You have the right to know: The categories of personal information we have collected about you; The categories of sources from which the personal information is collected; Our business or commercial purpose for collecting or selling personal information; The categories of third parties with whom we share personal information, if any; and The specific pieces of personal information we have collected about you. Please note that we are not required to: Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained; Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or Provide the personal information to you more than twice in a 12-month period.
Personal Information Sold or Used for a Business Purpose	In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know: The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and The categories of personal information that we disclosed about you for a business purpose. You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the sale of your personal information. If you exercise your right to opt-out of the sale of your personal information, we will refrain from selling your personal information, unless you subsequently provide express authorization for the sale of your personal information. To opt-out of the sale of your personal information, contact us or our Data Protection Officer (see “How To Contact Us” below).
Right to Deletion	Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will: Delete your personal information from our records; and Direct any service providers to delete your personal information from their records. Please note that we may not delete your personal information if it is necessary to: Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us; Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; Debug to identify and repair errors that impair existing intended functionality; Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law; Comply with the California Electronic Communications Privacy Act; Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent; Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us; Comply with an existing legal obligation; or Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Protection Against Discrimination	You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things: Deny goods or services to you; Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; Provide a different level or quality of goods or services to you; or Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services. Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your personal information.

12. COPPA

VacayMyWay is intended for a general adult audience and is not directed to children under the age of thirteen (13). We do not knowingly collect personal information from children under the age of thirteen (13).

13. Keeping Your Personal Information Secure

We have enacted reasonable and appropriate security measures to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so. While no company can guarantee absolute security, we have implemented physical, technological, and companywide processes to ensure your confidence in using the VacayMyWay platform.

14. Your Rights and Choices

You have certain rights and choices concerning your personal information as described in this Privacy Statement, including:

If you have established an account with VacayMyWay, you may change your communication choices by (1) logging into your account and changing your choices, or (2) contacting us as shown below in ‘How to Contact Us.’
You can update your information at any time by logging into your account or by contacting us.
If you do not want to receive promotional and marketing emails from us, you can unsubscribe at any time by clicking on the link identified as “Unsubscribe” in the email. You can also log into your account and change your communication settings. Even if you unsubscribe or opt out, you may still receive important messages from us related to your account or transactions. You will not be able to unsubscribe from these messages.
You can control our use of some cookies by following the information contained in our Cookie Statement. Please keep in mind that you may not be able to use some of all of the features of VacayMyWay if cookies are disabled.
For VacayMyWay’s mobile application, you can view, control, and manage the notifications settings, and your preferences un the ‘Settings’ menu of the application and of your device’s operating system.
If VacayMyWay processes your information based on your express consent, you have the right to withdraw your consent at any time. You can withdraw your consent by contacting us. If you withdraw your consent, it will not affect the lawfulness of processing that occurred before the withdrawal of consent. It will also not affect our processing of you personal information where it is based on a legal basis other than your consent.

15. How to Exercise Your Rights

If you would like to exercise any of your rights as described in this Privacy Policy, please contact us in one of the methods shown under ‘How to Contact Us’.

Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.

You will need to provide us with:

Enough information to identify you (e.g., your full name, address and customer or account number);
Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
A description of what right you want to exercise and the information to which your request relates.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.

Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

16. Changes to This Privacy Statement

This Privacy Statement was published on the Effective Date set forth at the beginning of the Privacy Statement.

We may change this Privacy Statement from time to time. When we do, we will inform you by posting a conspicuous notice concerning the changes to the website and by posting the new Privacy Statement.

17. How to Contact Us

Please contact us or our Data Protection Officer by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.

Our contact details are shown below:

Our contact details:
VacayMyWay
608 E. Hickory Street #128
Denton, Texas 76205
info@vacaymyway.com
(877) 822-2946

Our Data Protection Officer’s contact details:
VacayMyWay
Attn: Data Protection Officer
608 E. Hickory Street #128
Denton, Texas 76205
info@vacaymyway.com

18. Do You Need Extra Help?

If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).

Privacy Statement