Virtual Concierge Privacy Policy


Table of Contents

Changes to This Policy

We may update this Policy from time to time. If we do, we’ll let you know about any material changes, either by notifying you on the Site or by sending you an email. New versions of this Policy will never apply retroactively — we’ll tell you the exact date they go into effect. If you keep using the Virtual Concierge after a change, that means you accept this Policy.

Who We Are

Answer Anything LLC (creators of the Virtual Concierge Service, subsidiaries, affiliates, agents, representatives, consultants, employees, officers, and directors — collectively, “Virtual Concierge Service,” “VCS”, “we,” or “us”) provides services that help hospitality hosts from individual vacation rental owners, to large property management companies, to hotels (“Hosts”) add value to their guest’s experience using AI voice assistant apps and smart home technology. We are a Limited Liability Company based outside of Seattle, WA.

How This Policy Applies

This Policy describes the information we collect from you, how we use that information and our legal basis for doing so. It also covers whether and how that information may be shared and your rights and choices regarding the information you provide to us. If you see a capitalized word, it’s defined in our Terms of Use. We use cookies and similar technologies, as described under Cookies and other Technologies.
By using the Services offered by VCS, you’re acknowledging you have agreed to our Terms of Use and that you have read and understood this Privacy Policy and our Cookie Policy.

What We Collect and Receive

In order for you to create an account on VCS and use our Services, we need to collect and process certain information. Depending on your use of the Services, that may include:
  • Information you provide by completing forms on VCS— your name, your company name, email and postal addresses, telephone number, country of residence, login, and password details. We may ask for this information if you register as a user of the Services, subscribe to communication we offer, upload or submit content through VCS, or if you contact us;
  • Details of any requests or transactions you make through the Services. VCS partners with other companies (such as Braintree) for payment processing, and the payment information you submit is collected and used by them in accordance with their privacy policies (for Braintree’s, click here). VCS doesn’t store your payment information apart from the last four digits of your credit card or bank account (as applicable), expiration date, and country, which we may require for tax, government regulatory, and security purposes;
  • Information about your activity on and interaction with VCS, such as your IP address, the type of device or browser you use, and your actions on the Sites;
  • Information about the ways people visit and interact with our Sites, in the form of traffic analytics. You can opt out of being included in Google Analytics here. For more information about our use of data analytics to protect and improve our Services, see Cookies and other Technologies;
  • Communications you send to us (for example, when you ask for support, send us questions or comments, or report a problem);
  • Information that you submit on or to VCS in the form of comments, contributions to discussions, or messages to other users; and
  • The email address associated with your Amazon or Google account that you use to enable the VCS Services at your properties.
You may decline to provide us with your information. However, this will limit your ability to register for an account or use our Services.

How We Use This Information

We use the information we collect for the following purposes:
  • To keep your account secure and protect our Services (including to verify the identities of creators and prevent fraud and abuse);
  • To enable us to provide you with our Services, and to improve and promote our Services;
  • To create and administer your account, contact you, and customize your experience on VCS; and
  • To track and analyze use of the Services so that we can improve how VCS is performing and provide users with the best experience possible.

European Union Users

Data protection law in Europe requires a “lawful basis” for collecting and retaining personal information from citizens or residents of the European Economic Area. Our lawful bases include:
  • Performing the contract we have with you: In certain circumstances, we need your personal data to comply with our contractual obligation to deliver the Services.
  • Legal compliance: Sometimes the law says we need to collect and use your data. For example, tax laws may require us to retain records of payments made through our Services.
  • Legitimate interests: This is a technical term in data protection law which essentially means we have a good and fair reason to use your data and we do so in ways which do not hurt your interests and rights. We sometimes require your data to pursue our legitimate interests in a way that might reasonably be expected as part of running our business and that does not materially impact your rights, freedom or interests.
    For example, we may use identity, device, and location information to prevent fraud and abuse and to keep the Services secure. We may also send you promotional communications about our Services, subject to your right to control whether we do so.
    We analyze how users interact with our Sites so we can understand better what elements of the design are working well and which are not working so well. This allows us to improve and develop the quality of the online experience we offer all our users.

How This Information Is Shared

Information that's shared publicly
The only circumstance in which your information would be shared publicly is associated with user testimonials, reviews or comments. This information is generally shared anonymously, however we may ask for your permission to use your name. In those circumstances, your name is the only personal information shared, with your consent.
Information that isn't shared publicly
The following data will not be publicly displayed or revealed to other users:
  • Any payment information you provide;
  • Your password details;
  • Your IP address;
  • Your phone number;
  • Your address;
  • The name of your business;
  • The property address(es) where you use the virtual concierge;
  • Communications you send to us (for example, when you ask for support, send us questions or comments, or report a problem).
Information that's shared with trusted third-party services
We may share your information with certain trusted third-party services to help us provide, improve, promote, or protect VCS’s Services (like when we partner with payment processors, or use services that help us manage our ads on other sites). When we share data with third-party services that support our delivery of the VCS Services, we require that they use your information only for the purposes we’ve authorized, and that they protect your personal information at least to the same standards we do. We may also share information that’s aggregated and anonymized in a way that it doesn’t directly identify you.
Information that's shared to protect VCS and comply with the law
We do reserve the right to disclose personal information when we believe that doing so is reasonably necessary to comply with the law or law enforcement, to prevent fraud or abuse, or to protect VCS’s legal rights, property, or the safety of VCS, its employees, users, or others.
Links to other websites and services
Our Site may include links to other websites or services whose privacy practices may differ from VCS’s. When you use a link to an external site or service, the privacy policy and data processing disclosures for that site or service governs.

Retention

We will retain your information as long as your account is active, as necessary to provide you with the Services or as otherwise set forth in this Policy. We will also retain and use this information as necessary for the purposes set out in this Policy and to the extent necessary to comply with our legal obligations, resolve disputes, enforce our agreements and protect VCS’s legal rights.
We also collect and maintain aggregated, anonymized or pseudonymized information which we may retain indefinitely to protect the safety and security of our Site, improve our Services or comply with legal obligations.

Data Transfers

Because VCS is a US-based company, your information will be collected and processed in the United States. The United States has its own laws governing data protection and government access to information. The rules that protect your personal information under United States law may be different than in your home country. If you choose to use the Services, you need to agree to our Terms of Use, which set out the contract between VCS and its users.

Your Rights

Users residing in certain countries, including the EU, are afforded certain rights regarding their personal information. Except where an exception or exemption applies, these rights include the ability to access, correct, and request deletion of your personal information.
You can request a copy of your personal data from VCS, or modify or delete personal information that you have provided to us by contacting us at support@virtualconciergeservice.com. We may retain certain information as required by law or as necessary for our legitimate business purposes.

Security

We take security seriously, and the security of your personal data is important to us. We follow industry-standard practices to protect the data we collect and maintain, including using Transport Layer Security (TLS) to encrypt information as it travels over the internet. No method of transmission over the internet or electronic storage is completely secure, so VCS cannot guarantee its absolute security. Your account information is protected by a password, which you should choose carefully and keep secure.
We encourage the responsible disclosure of vulnerabilities of our Services by emailing support@virtualconciergeservice.com.

Cookies and other Technologies

What they are
Cookies are small data files that are issued to your device when you visit a website and that store information about your use of a service. Pixel tags (which are also called clear GIFs, web beacons, or pixels) are little snippets of code or tiny images embedded on websites and in email that help us learn how you interact with our site and emails.
Why we use them
VCS uses cookies and these other technologies to help recognize you as a repeat visitor and, to improve the quality of our Services.
How they work
When you visit VCS, our web server sends a cookie to your device, which allows us to recognize your device (but not the specific person using it). By associating the identification numbers in the cookies with other account information when, for example, you log in to our Services, we know that the cookie information relates to your user account. Similarly, pixel tags on VCS and in email communications help us identify how your device is being used to interact with VCS content. Some of the tags and cookies used by our Services are served by us, and some are served by trusted partners who are delivering services on our behalf.
Some examples of the types of cookies and other technologies VCS uses:
  • Authentication
    VCS uses authentication cookies and similar technologies to tell us when you’re logged in to VCS.
  • Security
    Cookies also help keep VCS secure by facilitating security features and allowing us to detect activity that might violate our rules and Terms of Use.
    These cookies help protect your account from being accessed by anyone other than you, alert you and us when your account is accessed, and provide capabilities that allow us to disable any active sessions you have (for example, when you log out or change your password).
  • Localization
    Some cookies help us provide localized experiences — for example, by making sure you see VCS in your preferred language.
  • Site features and services
    VCS uses cookies that provide functionality and help us deliver our products and services — for instance, by storing your preferences or by pre-filling the username field when you log in.
  • Performance
    Performance cookies help us route traffic between servers and understand how VCS is performing, so we can provide you with the best experience possible. We may use third party software development kits (SDK) in our Sites to collect information about activity in the app, the type of device and operating system it is running on and how the Services are functioning. For example an SDK may send us a report if the Service crashes, and reports on which features are used more than others.
  • Analytics and research
    Cookies and other technologies also help us to understand, improve, and research features and content on the VCS site. For example, we may use cookies to determine which types of browsers or devices are accessing VCS. You can opt-out of being included in Google Analytics here.
  • Social Media Platforms
    Cookies and other technologies make interacting with social media platforms more seamless. For example, when you’re signed into social media accounts while you use our Services, these technologies enable you to share content with your social network or, in some cases, log in using your social media credentials. These features are usually controlled by the social media platform you are using and are governed by its separate privacy policies and the preferences you set with that service.
  • Marketing
    Cookies help us deliver targeted advertisements on social media platforms, based on your activity on VCS, and to track the performance of those ads. This is sometimes referred to as online behavioral advertising. In some cases, our partners may use cookies to provide us with information about your interactions with their services. Those third-party cookies would be subject to the third party service’s policies.
    You can opt-out of online behavioral advertising. The Self-Regulatory Program for Online Behavioral Advertising program provides consumers with the ability to opt-out of having their online behavior recorded and used for advertising purposes. To opt out of having your online behavior collected for advertising purposes, click here.
    Certain choices you make are both browser- and device-specific.
You can control certain cookies
Your browser may give you the ability to control cookies. How you do so depends on the type of cookie. Certain browsers can be set to reject browser cookies. Blocking or deleting cookies may prevent you from using most of our Services. To find out more about how to enable, disable, or delete cookies from your web browser, please visit here. To control flash cookies, which may be used on certain websites from time to time, you can go here. Why? Because flash cookies cannot be controlled through your browser settings.
Our Do Not Track Policy
Some browsers have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals. If you block cookies, certain features on our sites may not work. If you block or reject cookies, not all of the tracking described here will stop.
Certain options you select are browser- and device-specific.

Data Protection Officer

To contact our Data Protection Officer, please email privacy@virtualconciergeservice.com.
You can contact us in writing at:
Answer Anything, LLC
30610 NE Tolt Hill Rd
Carnation, WA 98014
USA

Data Protection Authority

Subject to applicable law, if you are a citizen or resident of the European Economic Area, you also have the right to (i) object to VCS’s use of your personal information and (ii) lodge a complaint with your local data protection authority.

Children

People under 18 (or the legal age in your jurisdiction) are not permitted to use VCS on their own. VCS does not knowingly collect any personal information from children under the age of 13 and children under 13 are not permitted to register for an account or use our Services.
If you believe that a child has provided us with personal information, please contact us at support@virtualconciergeservice.com. If we become aware that a child under age 13 has provided us with personally identifiable information, we’ll delete it.
Updated: July 2018