I. Introduction

This Policy specifically outlines CPS Graphics Inc., DBA Tambourine and our subsidiaries (“Tambourine”, “us”, “we”, or “our”) Privacy Policy for Tambourine’s data collection, use, and disclosure practices (“Privacy Policy”) in connection with Tambourine’s Venuelocity website (the “Website”). This Privacy Policy applies to any page on the Website, even if that page displays information or trademarks of Tambourine’s Client.

This Privacy Policy applies to all visitors and users of our Website and also to those Consumers whose Personal Information we may have collected or processed.

By continuing to visit and use the Website, You are agreeing to the terms of this Privacy Policy. If You do not agree, then please exit the Website and close Your browser.

If You are a Consumer of one of our Clients and looking for more information on how to opt out of our use of Your Personal Information or are looking to otherwise exercise any of Your Privacy Rights, please see sections IX, XI, XII, and XVI with regards to the same.

II. Definitions

“Client(s)” means a business that has hired us to provide our services.

“Consumer(s)” means a natural person whose Personal Information that we may have collected and processed.

“Personal Information” or “Personal Data” means any information relating to an identified or identifiable individual that is collected via our Website. Personal Information may include a Visitor’s or a Consumer’s: full name, physical address, email address, IP address, or other identifier such as from a cookie.

Personal Information does not include any aggregate or anonymized data that may have been created from Personal Information but can no longer be used to identify, relate to, or could reasonably be linked to a Visitor or Consumer.

“Sensitive Personal Information” means any data about a natural person that reveals a racial or ethnic origin, political opinion, religious belief, philosophical belief or trade union membership. It also includes a natural person’s genetic and biometric data, and data concerning their health, sex life or sexual orientation.

“You” or “Your” means a Consumer and a Visitor.

“Visitor(s)” means a natural person who visits our Website, but is not known to be a Consumer.

III. Information That We Collect From You When You Visit Our Website

We collect certain Personal Information from You in order to operate our Website effectively and provide You with the best experiences when You visit and use it.

a. Information Provided By You

When You consent to receive newsletters, marketing emails or general hotel marketing , we will collect certain Personal Information about You such as Your name, e-mail address, phone number, and company name (which may also be Your employer’s name). We will also collect certain Personal Information about You when You fill out a contact form or speak with our virtual assistant, or otherwise provide Your Personal Information to us in order to be in contact or receive information from us.

If You visit one of our Client’s websites and fill out a form for more information about booking a stay or an event, Tambourine is not involved in any way; such information is subject solely to the Client’s own privacy policies.

b. Information Collected On The Website And Via Other Automatic Means

We also may use various technologies to collect information from Your computer or device and about Your activities on our Website.

Information Collected Automatically

We may automatically collect information from You when You visit the Website. This information may include Your IP address, location data, Your browser type and language, access times, the content of any undeleted cookies that Your browser previously accepted from us, referring or exit website address, internet service provider, date/time stamp, operating system, locale and language preferences, and system configuration information.

Google Analytics

We also use Google Analytics on our Website and to help provide our services to Consumers, Visitors, and Clients. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our website. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on our websites available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: 
https://www.google.com/intl/en/policies/privacy/

Cookies

When You visit our Website, we may assign Your device one or more cookies to facilitate access to our site and to personalize Your online experience. Through the use of a cookie, we also may automatically collect information about Your online activity on our site, such as the web pages You visit, the links You click, and the searches You conduct on our site. Most browsers automatically accept cookies, but You can usually modify your browser setting to decline cookies.

A cookie is a small text file that is stored on a user’s computer for record keeping purposes. Cookies can be either session cookies or persistent cookies. A session cookie expires when You close your browser and is used to make it easier for You to navigate our website. A persistent cookie remains on your hard drive for an extended period of time.

We use cookies to personalize content and ads, to provide social media features and to analyze our traffic. We also share information about Your use of our site with our social media, advertising and analytics partners, who may combine it with other information that You’ve provided to them or that they’ve collected from Your use of their services.

Other Technologies

We may use standard Internet technology, such as web beacons, digital visitor management technology, and other similar technologies, to track your use of the Website. We also may include web beacons in promotional e-mail messages or newsletters to determine whether messages have been opened and acted upon. The information we obtain in this manner enables us to customize the services we offer to users of the Website to deliver targeted advertisements and to measure the overall effectiveness of our online advertising, content, programming, or other activities. Web beacons (also known as clear gifs, pixel tags or web bugs) are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users or to access cookies. Unlike cookies, which are stored on your device, web beacons are embedded invisibly on the web pages (or in emails) and are about the size of the period at the end of this sentence. Web beacons may be used to deliver or communicate with cookies, to count visitors to certain pages, and to understand usage patterns. We also may receive an anonymous identification number if You come to our Website from an online advertisement displayed on a third-party website.

c. Information collected from Third Parties 

We may also receive information about You from other third-party service providers, such a telemarketers, MailChimp, Rack Space, Amazon Web Services, and others. In most cases, this will be information that You have provided directly to these third-parties, but in some situations, this could be information that has been collected about You by these third-parties. Additionally, we may also receive information about You from:

Google Adwords

We may also receive information about You from Google AdWords remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: https://www.google.com/settings/ads

Google also recommends installing the Google Analytics Opt-out Browser Add-on
https://tools.google.com/dlpage/gaoptout for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page:
https://www.google.com/intl/en/policies/privacy/

Meta Marketing

We may also receive information about You from Facebook marketing services which is provided by Meta Platforms, Inc. You can opt out of this sharing by visiting Meta and following their instructions. You can learn more about Meta’s privacy practices and policies here: https://www.facebook.com/privacy/policy/.

Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.

IV. Why We Collect Your Information

To Service Our Website

We use information collected to ensure that Our Website is working as intended and for analytics purposes, to understand how our Website is operating and learn how it can be improved. We also use this information as needed for auditing purposes as well.

For Marketing Purposes

If You have filled out a contact form with us, signed up for a newsletter, we may use this information to send You marketing communications including other newsletters and emails. We may also use this information to send You marketing communications. You can opt out of receiving these communications at any time by clicking the “opt out” link at the bottom of these emails or by emailing us directly at
privacy@tambourine.com.

To Provide Our Services To Our Clients

We use information collected to provide our services to our Clients. Generally, our services are to support marketing efforts for resorts and hotels. We help to support our Clients’ marketing efforts by enabling and supporting the provision of information about their business and services to their customers and potential customers, which may include You.

To Evaluate And Improve Our Customer Service

We may use this information to ensure we are providing the highest level of customer service, and to identify any potential gaps or potential improvements to the same.

In Order To Respond From Requests From You

If You have requested further information or in any other way requested that we contact You, we will use Your Personal Information to respond to such a request.

For Our Legal Purposes

We also collect information in order to comply with certain legal rules and regulations that we are subject to.

V. How Long Do We Store and Maintain Your Personal Information?

We only store and maintain Your Personal Information for as long as is necessary to fulfill the purpose for which it was collected. For example, if You sign up to receive marketing emails, we will store and maintain Your Personal Information to continue to send You these materials until You opt out of receiving such communications. With regards to Your Personal Information collected for our analytics purposes and used to help maintain and improve our Website, we only store and maintain that information until it is aggregated and used to create a new anonymous data set that no longer contains Your Personal Information, and then delete the underlying Personal Information once that new data set has been created.

VI. We Do Sell And Share Your Personal Information 

Tambourine collects Your Personal Information on the Website, and then shares it with our Clients via the provision of our marketing services. Because our clients are paying for our services, this could be considered a sale of Your Personal Information. We also share Your Personal Information with email marketing tools operated by third parties, such as Mailchimp, to facilitate the deployment of marketing emails. We do not otherwise sell Your Personal Information to third parties. We do share Your Personal Information for cross-contextual advertising purposes with our advertising partners. To withdraw Your consent or exercise any You may make that request at our “Do Not Sell My Personal Information” form at
www.tambourine.com/do-not-sell-my-data.

VII. Who Do We Share Collected Personal Information With?

Tambourine shares Your Personal Information when necessary to members of our internal team and our service providers. We also share Your Personal Information with our Clients and for use in their marketing campaigns, as well as in Our marketing campaigns. We also share Your Personal Information with email marketing tools operated by third parties, such as Mailchimp, to facilitate the deployment of marketing emails.

When we share Your Personal Information with our service providers, we ensure that they are either contractually obligated to secure Your Personal Information in the same way that we do and further that they cannot sell or further share Your Personal Information without Your consent, or have legal authority to receive Your Personal Information.

Specifically, the service providers that we may also generally share Your Personal Information with are:

• IT service providers for hosting, management of IT systems, backup, provision and maintenance of IT networks, backup networks, etc.;
• marketing support such as email providers, such as Mailchimp; and
• Service providers for archiving, etc.

Depending on the need, We may also have to share Your Personal Information with:

• Our Legal Representatives; and
• Authorized third parties such as Law Enforcement, Courts, Supervisory Authorities and Auditors.

VIII. How Do We Secure Your Personal Information?

Tambourine maintains a comprehensive information security program that employs commercially available physical and IT securitization tools, including but not limited to:

• Commercially available and sufficient firewalls;
• Segmented Data Storage;
• Multi-factor authentication;
• Industry-standard SSL-encryption to enhance the security of the data transmissions; and
• Policies providing for least privileged access to data across our organization.

No method of data storage or data transmission can be guaranteed to be completely secure. If we suffer a data breach, we will report the same to You in compliance with relevant data breach notification laws.

IX. California Residents Legal Disclosures

Categories of Personal Information That We Collect:

Sale Or sharing Of The Personal Information And Sensitive Information Of Persons Under The Age Of 16

We do not collect, sell, or share the Personal Information of persons under 16 years of age.

Use And Disclosure Of Sensitive Information

We may collect or share the Sensitive Information of Consumers, but only with regards to provide the services or the goods that those Consumers had requested more information about or opted into receiving more information about.

Sale Or Sharing Of Your Personal Information For Our Business Purposes

As noted above, Tambourine collects Your Personal Information on our Website, and then shares it with our Clients via the provision of our marketing services. Because our Clients are paying for our services, this could be considered a sale of Your Personal Information. Additionally, we use analytics services to process data, which may include Your Personal Information, and under California law that may be considered a sale as well. We also share Your Personal Information with email marketing tools operated by third parties, such as Mailchimp, to facilitate the deployment of marketing emails. We do not otherwise sell Your Personal Information to third parties. We do share Your Personal Information for cross-contextual advertising purposes with our advertising partners. To withdraw Your consent or exercise any You may make that request at our “Do Not Sell My Personal Information” form at www.tambourine.com/do-not-sell-my-data

We do not share Your Personal Information for any other reason besides for our business purposes as noted below.

The categories of third parties that we need to share your Personal Information with and the Categories of Personal Information that we share with those parties are:

Why We Collect This Information From You

We use this information from You to support and run the Website, to provide our services to our Clients, to facilitate Your application for employment, and for our business purposes as outlined above.

Categories Of Personal Information That We Share For Our Business Purposes:

We collect and share Your Personal Information for our business purposes. Specifically, these categories of business purposes are:

• Auditing – We may share this information with our third-party vendors, partners and service providers, and our own auditors related to an audit of our business.
• To Provide Our Services to Clients – We share this information with our Clients in order to provide our services and support our Client’s marketing efforts.
• Service Improvements – We may share this information with our third-party vendors, other partners, and service providers in order to improve our services, create new services and products, offer new products, and to ensure that our services are working as intended (to identify bugs and errors, and repair them).
• Service Partners – We may share this information our third-party vendors, other partners, and service providers in order to have them perform their services for Us, pursuant to a written contract that includes the notified purposes permitted by California Law.
• Security and Legal Issues – We may share this information with law enforcement or other individuals pursuant to a valid subpoena or other legal obligation, our third-party vendors, other partners, and service providers in order to detect, prevent, and investigate security incidents.

Your Rights Under California Law

You, or Your authorized agent, can request information on the specific pieces of Personal Information we have collected about You by emailing privacy@tambourine.com. You can also request that we disclose how we have collected, used and shared Your Personal Information over the past 12 months, including the categories of Personal Information we collected and our purposes for doing so. You may also request the categories of the sources of that information, the categories of the third parties with whom we have shared this information with for a business purpose, and our business purpose for doing so.

• You have the right to correct inaccurate Personal Information that we have collected or maintain about You.
• You have the right to opt out of sale and sharing of Your Information.
• You have a right to be notified when we collect information from You, and we cannot collect new categories of information from You without notifying You first.
• You have the right to limit our sharing of Your Personal Information.
• You have the right to not be discriminated against for exercising these rights.
• You have the right to ask us to delete Your Personal Information. Please note that if You are a job applicant and our collection of Your Personal Information and Sensitive Information is done in connection with the provision of Your application for employment and eventually the provision of Your employment, then we must maintain certain information related to Your employment pursuant to various regulations. Thus, if You request that we delete Your Personal Information, we may not be able to so right away if subject to those legal requirements. However, as soon as we legally can delete your information we will.

How to Exercise Your Rights

If You would like to exercise any of the rights listed above with regards to Your Personal Information, then please contact us, or have Your registered agent contact us, at privacy@tambourine.com or via phone at
954-975-2220.

If You want to opt out of the sale and sharing of Your Personal Information, You can do so here: “Do Not Sell My Personal Information” form at www.tambourine.com/do-not-sell-my-data

If You want to review and request changes to Your Personal Information, You may also email or call us as noted below, and we will then provide You with detailed instructions on how to do so.

X. California “Shine the Light” Notice

The California Civil Code permits California Residents with whom we have an established business relationship to request that we provide You with a list of certain categories of Personal Information that we have disclosed to third-parties for their direct marketing purposes during the preceding calendar year. To make such a request please send an email to privacy@tambourine.com. Please mention that You are making a “California Shine the Light” inquiry.

XI. For EU Data Subjects – General Data Protection Regulation (Regulation (EU) 2016/679)(“GDPR”)

What Information Do We Collect From EU Data Subjects?

We collect the same Personal Information and Sensitive Information (together, “Your Data”) from all Consumers as outlined above.

How Do We Collected Your Data?

We collect Your Data as outlined above.

How Will We Use Your Data?

We use Your Data to provide our Services to the our Clients.

How Do We Store Your Data?

We securely store Your Data as detailed above. We only store Your Data for as long as necessary to support and facilitate the provision of our services to Clients. Once the legal requirement to store Your information has expired, we securely delete it.

What are Your Data Protection Rights?

As an EU Data Subject, You have the following rights:

• The Right to Access Your Data - including asking for copies of Your Personal Information and Sensitive Information. We are entitled to charge You a small fee to provide You with the same.
• The Right to Rectification of Your Data - including the right to ask us to correct any inaccurate data and complete any incomplete data.
• The Right to Erasure of Your Data - including asking us to delete copies of Your Data. Please note that we may not be able to immediately delete certain portions of Your Data based on legal rules and requirements, however, once those restrictions have expired, we will delete the same.
• The Right to Restrict Processing of Your Data – including the right to request that we restrict processing of Your Data under certain circumstances. Again, legal requirements and obligations may limit our ability to fully restrict the processing of Your Data.
• The Right to Object to the Processing of Your Data - including the right to request that we stop processing Your Data under certain circumstances. Again, legal requirements and obligations may limit our ability to fully stop processing of Your Data.
• The Right to Data Portability - including the right to request that we transfer Your Data to another organization or directly to You, under certain circumstances. Again, legal requirements and obligations may require us to also maintain copies of Your Data even if we transfer it as requested.

How can You Contact Us?

If You have any questions about this Policy, Your Data that we have, or would like to exercise any of Your data protection rights, then please email us at privacy@tambourine.com.

How to Contact the Appropriate Authority?

If You wish to report a complaint or feel that we have not addressed your concerns in a satisfactory manner, then You may contact Your local Data Protection Authority which may be found here:
https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.html

XII. Virginia Consumer Data Protection Act Privacy Notice (“VCDPA”)

Categories of Personal Information that we process:

Purposes for Processing Your Personal Data

We Your Personal Data to provide our services and products to You and for our business purposes as described above.

Categories of Third Parties that we share Your Personal Data With

We may need to share Your Personal Data with the following Categories of Third Parties:

• Our Service Providers;
• Data Service Providers;
• Legal Representative;
• IT Service Providers;
• Law Enforcement, Courts, or other related Legal third parties that are not our legal representatives;
• Auditors; and
• Accounting Representatives.

We do sell Your Personal Data for Targeted Advertising

As noted above, we do sell Your Personal Data.

How to Exercise Your Privacy Rights under the VDCPA

If You would like to exercise any of Your rights under VSCPA, then please contact us
at privacy@tambourine.com.

If You want to review and request changes to Your Personal Information, You may also email or call us as noted below, and we will then provide You with detailed instructions on how to do so.

XIII. Children’s Personal Information 

The Website is not directed towards or marketed to children under the age of 16. We do not knowingly collect any Personal Information concerning or from children under the age of 16. If we learn that we have collected personal data from a child under 16 without parental consent, we will take steps to delete the information as soon as possible.

XIV. Third-Party Tracking on The Website

Third-parties may be using cookies or other technologies to collect Your Personal Information as You navigate through the internet including from the Website. As described above, You may decline these third-party cookies by changing Your browser settings.

XV. Do Not Track (“DNT”) Settings 

DNT is a setting on some web browsers or mobile devices that can be turned on to instruct websites to disable tracking of your web browsing activities. DNT is not currently widely adopted and does not have clear standards or guidelines as to how websites are to interpret it. Additionally, its signals can affect the functioning of certain websites. As such, Tambourine does not generally respond to these signals.

XVI. How To Contact Us

If You have any questions regarding this Policy or our privacy practices, or the privacy policy and practices of our domestic or foreign service providers, You can contact us at privacy@tambourine.com.

If You contact us by e-mail, You should be aware that e-mail transmissions might not be secure. Information You send by e-mail could be viewed in transit by a third party. We will have no liability for disclosure of your information due to errors or unauthorized acts of third parties during transmission.

XVII. Changes To This Privacy Policy

Any changes to the Privacy Policy will be posted directly on our Website and reflected with a new Effective Date at the top of this Privacy Policy. We encourage You to review the Online Policy each time You visit our Website to see if it has been updated since Your last visit.