Ski Butlers Privacy Policy

SKI BUTLERS PRIVACY POLICY

Last updated: August 232022

Ski Butlers is concerned about your privacy and security. We take extra steps to ensure your information is kept confidential.

1) APPROACH TO PRIVACY

Ski Butlers Holdings, LLC, doing business as Ski Butlers (“Ski Butlers,”​“we,”​“our,” or​“us”) is committed to protecting the privacy of its customers. This privacy policy sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you (“personal information”) and information regarding our use of cookies and similar technologies.

Ski Butlers operates a ski & board delivery service throughout the United States of America, Canada and has partnered with Rental Republic to provide ski and board delivery services throughout France. Customers can reserve and rent boots, skis, snowboards, and poles via our website (our​“Website”) located at www.skibut​lers​.com or by contacting one of our delivery locations directly (the​“Delivery Service”).

This privacy policy governs any personal information collected through the Delivery Service.

Before accessing or using the Delivery Service, please ensure that you have read and understood our collection, storage, use and disclosure of your personal information as described in this Privacy Policy. By accessing or using the Delivery Service, you are accepting and consenting to the practices described in this Privacy Policy.

2) COLLECTION AND USE OF PERSONAL INFORMATION

Voluntarily Submitted Personal Information.

Ski Butlers collects specific personal information about you when you voluntarily submit information directly to us by filling in forms on our Website or by corresponding with us by phone, email or otherwise.

When you reserve and rent boots, skis, snowboards, poles, etc. via the Delivery Service, Ski Butlers collects certain personal information necessary to fulfill the reservation/​order. Specifically, Ski Butlers collects rental profile information that consists of your name, gender, age (date of birth), weight, height, skier/​snowboarder ability, shoe size, location of delivery, and other information necessary to fulfill the reservation/​order. Further, Ski Butlers collects account information that is associated with your reservation/​order. Specifically, Ski Butlers collects payment information that consists of your name, billing address, phone number, and credit card.

Additionally, we will collect the personal information that you provide when you: 1) register to use our Website; 2) utilize a social media platform where we operate an account and engage with our account; 3) subscribe to the Ski Butlers Plus program; 4) enter a competition, promotion or survey conducted by us; 5) when you report a problem with our Website; 6) or, when you use some other feature of the Website.

In the event that you choose not to provide personal information, Ski Butlers may not be able to provide the Delivery Service to you or respond to your other requests.

Information Provided by Third- Parties.

Ski Butlers may receive personal information about you from individuals or corporate entities which are users of the Delivery Service (“Subscribers”). Specifically, if a Subscriber is reserving or renting boots, skis, snowboards, poles, etc. via the Delivery Service for you, Ski Butlers will collect information necessary to generate your rental profile (name, gender, date of birth, weight, height, skier/​snowboarder ability, shoe size, location of delivery, and other information necessary to fulfill the reservation/​order).

Ski Butlers may receive personal information about you if you use any referral service or referral website, including the website, rental​re​pub​lic​.co​.uk. Further, Ski Butlers works closely with third parties for marketing purposes (including, for example, advertising networks, analytics providers, search information providers) and may receive information about you from them, subject to your agreements with them.

Ski Butlers may automatically collect personal information about you using cookies and other tracking technologies, regarding: 1) how you access and use the Website; 2) information about the device and operating system you use to access the Website; and 3) where you are located at the time you accessed and used the Website.The technologies we use for automatic data collection do not collect any sensitive information (as defined under applicable laws) about you.

Categories of Personal Information, Retention Periods, and Legal Basis for Processing

At the end of this Privacy Policy, Table 1 sets out the categories of personal information you provide to us and that we receive from other sources and how we use that information. The table also lists the legal basis which we rely on to process the personal information and information as to how we determine applicable retention periods.

At the end of this Privacy Policy, Table 2 sets out the categories of personal information we collect about you automatically and how we use that information. The table also lists the legal basis which we rely on to process the personal information and information as to how we determine applicable retention periods.

3) DISCLOSURE OF PERSONAL INFORMATION

Sharing with Third- Parties.

We will not share your personal information with any third parties except as described in this privacy policy or in connection with the Delivery Service. We may share your information with selected third parties, including:?

  • Ski Butlers’ Franchisees;
  • Rental Republic (a Ski Butlers’ affiliate that provides services on Ski Butlers’ behalf in Europe);
  • Website, Applications, and Server providers that maintain and service the Website and Ski Butlers’ data servers;
  • Payment processors for the purpose of fulfilling relevant payment transactions; and
  • Analytics and search engine providers that assist us in the improvement and optimization of our Website.

In addition, we may disclose your personal information to a buyer or other successor in the event of a merger, divesture, restructuring, reorganization, dissolution, or other sale or transfer of some of all of Ski Butlers’ assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding, in which personal information held by Ski Butlers is among the assets transferred or otherwise shared.

Disclosure Pursuant to Legal or Regulatory Obligations.

In certain situations, Ski Butlers has a duty to disclose your personal information in order to comply with any legal obligation. For example, Ski Butlers may be required to disclosure your personal information pursuant to a lawfully issued subpoena or court order.

Ski Butlers may disclose your personal data in order to enforce or apply our terms and conditions of service and other agreements.

Ski Butlers may disclose your personal data to protect the rights, property, or safety of Ski Butlers, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.

4) Website Reviews and Testimonials.

With consent, Ski Butlers may display personal testimonials of satisfied customers on the Website, along with other endorsements. If you wish to update or delete your testimonial, you can contact us at [email protected]​skibutlers.​com.

5) MARKETING AND ADVERTISING.

In the event that you have signed up for Ski Butlers’ ENEWSLETTER, Ski Butlers may contact you, from time to time, with relevant information about Ski Butlers, the Delivery Service, our other products and services that we offer. For some messages, Ski Butlers may use personal information we collect about you to help us determine the most relevant information to share with you.

If you want to be removed from Ski Butlers’ email or mailing lists, please email Ski Butlers at, [email protected]​skibutlers.​com or call 18777547754. Additionally, you can be removed from our marketing lists by following the unsubscribe link at the bottom of our emails.

6) STORING AND TRANSFERRING PERSONAL INFORMATION

Security.

All information you provide to us is stored on secure servers in a controlled environment with limited access. The information will be stored utilizing encrypted database tables in an SQL server database.

Since Ski Butlers cannot guarantee the security of your personal information transmitted to our Website, please note that any personal information transmitted to Ski Butlers is done at your own risk. However, once Ski Butlers receives your personal information, Ski Butlers will use strict procedures and security features to try to prevent unauthorized access.

International Transfers of your Personal Information.

Ski Butlers is based in the United States and our Website is maintained in the United States. The personal information that Ski Butlers collects from you through our services may be transferred to, stored at, and processed in the United States and other destinations outside the European Economic Area (“EEA”) or other country in which you are located. This includes processing by us, our affiliates, our third party service companies and other third parties as described in this privacy policy. You explicitly consent and agree to such transfer, storing and/​or processing of your personal information outside the EEA or other country in which you are located. You understand that data stored in the United States may be subject to lawful requests by the courts or law enforcement authorities in the United States. The United States may not have data protection laws that are as comprehensive or protective as those in your country of residence; however, our collection, storage and use of your personal information will at all times be in accordance with this privacy policy.

7) RETAINING YOUR INFORMATION

Ski Butlers will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of our legitimate business interests and satisfying any legal or reporting requirements.

To determine the appropriate retention period for personal information, Ski Butlers takes into consideration the following information: 1) the amount, nature, and sensitivity of the personal information; 2) the potential risk of harm from unauthorized use or disclosure of your personal information; and, 3) the purposes for which we process your personal information and the applicable legal requirements.

8) REFER-A-FRIEND PROGRAM

Ski Butlers operates a referral program for our Delivery Service. Through that program, you may choose to provide Ski Butlers with names and email addresses of individuals who you feel would be interested in learning more about our products and services in exchange for a chance to win free ski rentals. Ski butlers will store the contact details in order to track the success of our referral service. In the event that the referred individual desires that we remove their contact details from our database, the referred individual may contact us at any time at [email protected]​skibutlers.​com or call 18777547754.

Prior to providing Ski Butlers with the names and email addresses of the individuals you would like to refer through the program, you agree to obtain the prior consent of those individuals and provide them with the information as to how we handle their personal information as described in this privacy policy.

9) YOUR RIGHTS IN RESPECT OF YOUR PERSONAL INFORMATION

In accordance with applicable privacy law, you have the following rights in respect of your personal information that Ski Butlers holds:

Right of access and portability.

The right to obtain access to your personal information along with certain information, and to receive that personal information in a commonly used format and to have it ported to another data controller.

Right to rectification.

The right to obtain rectification of your personal information without undue delay where that personal information is inaccurate or incomplete.

Right to erasure.

The right to obtain the erasure of your personal information without undue delay in certain circumstances, such as where the personal information is no longer necessary in relation to the purposes for which it was collected or processed.

Right to restriction.

The right to obtain the restriction of the processing undertaken by us on your personal information in certain circumstances, such as where the accuracy of the personal information is contested by you, for a period enabling us to verify the accuracy of that personal information.

Right to object.

The right to object, on grounds relating to your particular situation, to the processing of your personal information, and to object to processing of your personal information for direct marketing purposes, to the extent it is related to such direct marketing.

If you wish to exercise any one of these rights, please contact us using the contact details at the end of this privacy policy. Upon request, we will provide you with information about whether we hold any of your personal information. You may access, correct or request deletion of your personal information by logging into your account, or by contacting us at [email protected]​skibutlers.​com or call 18777547754. We will respond to your request within 30 days.

If you reside in the European Union, Ski Butlers is the controller of your personal information for purposes of European data protection legislation. You also have the right to lodge a complaint to your local data protection authority. Information about how to contact your local data protection authority is available at https://​ec​.europa​.eu/​i​n​f​o​/​i​n​d​ex_en

10) COOKIES AND SIMILAR TECHNOLOGIES

Ski Butlers’ Website uses weblogs and similar technologies (collectively referred to as cookies) to distinguish you from other users of our Website. The cookies contain the domain name or IP address from which you connect to our site, the date and time you access the site, search terms, and the pages visited. Ski Butlers makes periodic checks of the types of browsers/​operating systems used to access its Website and of the websites/​applications that you accessed the Website.

Ski Butlers’ use of cookies helps it enhance and personalize your user experience, to monitor and improve the Website, and for other internal purposes. As is true of most websites, we gather this information automatically. The information we may collect is described in detail in Table 2.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/​performance cookies or targeting cookies.

You may be able to block some cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies you may not be able to access all or parts of the Website.

Social Media.

Our Website includes social media features, such as Facebook Like button and an Instagram Follow Ski Butlers button. These features may collect your IP address and other personal information. Please be aware that the social media features and widgets on our Website will direct you to a third-party Website or Application, and your interactions with these features are governed by the privacy policy of the company providing it.

11) LINKS TO THIRD PARTY SITES

The Website may, from time to time, contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.

12) PERSONAL INFORMATION OF CHILDREN

Ski Butlers’ Delivery Service is not directed at persons under 16 and Ski Butlers does not intend to collect personal information from children under 16 in our capacity as a controller except when such information is provided directly to us by the child’s legal guardian or parent for the sole purpose of renting ski or snowboarding equipment. If you become aware that a child has provided Ski Butlers with personal information without the appropriate consent, then please contact us using the details below so that we can take the appropriate steps in accordance with our legal obligations and this privacy policy.

13) CHANGES TO THIS POLICY

Ski Butlers may update this privacy policy from time to time and so you should review this page periodically. When we change this privacy policy in a material way, we will update the​“last modified” date at the beginning of this privacy policy. Changes to this privacy policy are effective when they are posted on this page.

14) NOTICES TO CUSTOMERS

In the event that Ski Butlers needs to provide you with information regarding your personal information or other matters (including for legal, marketing or other business-related purposes), Ski butlers will select what we believe is the best way to get in contact with you. For most purposes, Ski Butlers will attempt to contact you either by email or by placing a notice on our Website. The fact that Ski Butlers may send notices to from time to time will not stop you from being able to opt-out of certain types of contact as described in this privacy policy.

15) CONTACTING SKI BUTLERS

Regardless of your location, any questions, comments and requests regarding this privacy policy are welcome and should be addressed to our Data Protection Officer, Mike Cremeno, at [email protected]​skibutlers.​com. Communication can also be addressed to:

Ski Butlers Holdings, LLC

1821 Sidewinder Dr., STE 1

Park City, UT 84060 USA

TABLE 1

Category of Personal information

Ski Butlers’ use of Personal Information

Legal Basis for the Processing

Contact information and basic personal details, including rental profiles (name, phone number, address, location, IP address, e‑mail address and when applicable: gender, age, height, weight, skier ability, etc.)

We use this information to communicate with you, including sending statements, news, alerts and marketing communications.

We use this information to deal with enquiries and other requests made by or about you, including customer service issues, relating to the Delivery Service. 

We use this information to operate, maintain and provide to you the

equipment that you reserved or rented.

The processing is necessary for our legitimate interests, namely for marketing purposes, and for communicating with you effectively and responding to your queries.

The processing is necessary for our legitimate interests, namely for the fulfillment of the services and equipment ordered by you and to ensure that the equipment reserved by you is safe for your use.

Payment information.
Details such as your credit card or other financial information.

We use this information to facilitate payment for use of the Delivery Service and to detect and prevent fraud.

The processing for facilitating payment is necessary for the performance of our contract with you (namely our Terms of Service).
The processing is necessary for our legitimate interests, namely the detection and prevention of fraud

Correspondence and comments. When you contact us directly, e.g. by email, phone, mail, or when you interact with customer service, we will record your comments and opinions.

To address your questions, issues and concerns and resolve your customer service issues.

The processing is necessary for our legitimate interests, namely communicating with you effectively for the purposes of resolving your issues.

All personal information set out above.

We will use all the personal information we collect to operate, maintain and provide to you the features and functionality of the Delivery Service, to monitor and improve the Delivery Service, our Website and business, for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes, to keep the Website safe and secure and to help us develop new products and services.

The processing is necessary for our legitimate interest, namely to administer and improve the Delivery Service, our business and develop new services.


TABLE 2

Category of Personal Information

Ski Butlers’ use of Personal Information

Legal Basis for the processing

Information about how you access and use the Delivery Service.For example, the website from which you came and the website to which you are going when you leave our Website, your social media profiles, how frequently you access the Delivery Service, the time you access the Delivery Service and how long you use it for, whether you open emails or click the links contained in emails, whether you access the Delivery Service from multiple devices, and other actions you take on the Delivery Service.

We also gather information, which may include Internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/​exit pages, operating system, date/​time stamp, and/​or clickstream data.

We use this information to: 1) conduct market analysis, monitor the Delivery Service and how it is used in order to and improve our business and help us develop new products and services; 2) generate marketing leads and determine news, alerts and other products and services that may be of interest to you for marketing purposes.

The processing is necessary for our legitimate interests, namely: to conduct relevant analysis to improve the Delivery Service generally and for marketing purposes.

Information about your device. We also collect information about the computer, tablet, smartphone or other electronic device you use to connect to the Delivery Service. This information can include details about the type of device, unique device identifying numbers, operating systems, browsers and applications connected to the Delivery Service through the device, your Internet service provider or mobile network, your IP address.

We use this information to: 1) enable the Delivery Service to be presented to you on your device; 2) operate, maintain and provide to you the features and functionality of the Delivery Service; 3) to monitor and improve the Delivery Service and business, and to help us develop new products and services.

The processing is necessary for our legitimate interests, namely: to tailor the Delivery Service to the user and to improve the Delivery Service generally.