Last Updated March 28, 2022
- Personal Information
- Identifiers (e.g., name, email, telephone number, address, username);
- Sensitive Personal Information (e.g., precise geolocation; race/ethnic origin; religious beliefs; contents messages when we are not the recipient);
- Legally protected information (e.g., race, citizenship, marital status, sex);
- Employment-related information (e.g. current or past employment);
- Non-public educational information, including information protected under the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99);
- Biometrics (e.g., DNA, face/voice prints, health data) and audio, electronic, visual, thermal, or olfactory information;
- Inferences drawn from Personal Information to create a profile about preferences, characteristics, trends, predispositions, behavior, attitudes, intelligence, and aptitudes;
- Commercial information (e.g., products/services purchased, obtained, or considered); and
- Internet or other similar activity (e.g., browsing history; content interactions).
Information that is not protected as Personal Information includes publicly available information; aggregated information (meaning data summaries or reports with the Personal Information removed); or de-identified information that cannot be easily linked back to the individual.
- Children’s Privacy
Our Services are not directed to children under 18. We do not knowingly collect Personal Information from children under 18. If we learn we have collected or received Personal Information from a child under 18, we will delete that information. Please contact us at [email protected] if you believe we have received information from a child under 18 or any unauthorized information.
- Categories and Sources of Personal Information Collected
Adrift may collect Personal Information (a) with your consent; (b) if we have a legitimate interest in doing so; or (c) as authorized or required by law. We only collect, use, retain, and disclose Personal Information as reasonably necessary and proportionate to provide our Services or for other purposes that we disclose to you and are compatible with the context of how we collected your Personal Information. During the preceding 12 months, we have collected Personal Information in the categories of identifiers, commercial information, and internet or similar activity. We collect this information from the following sources:
- Directly from you when you use our Services, with your consent. You provide Adrift with your Personal Information when you make a reservation with Adrift, fill out one of our forms, sign up to receive our emails, or communicate with us by email, phone or otherwise. In each case, we will collect identifiers like your name, email address, birthdate, phone number, and mailing address to the extent necessary to provide you with the requested Services. If you create an account with us, we will collect your email address and a password and issue a member number to you. You can also choose to provide commercial information and other Personal Information to complete your account profile or make requests related to a reservation. We collect this information with your consent, and we use it to book and manage your reservation, provide you with other Services you have requested, and to communicate with you according to your preferences.
- Indirectly from your use of our Services, with a legitimate interest. We automatically collect technical data about your use of our Services. For example, we may collect data about your (i) browsing history; (ii) device information (e.g., IP address, browser type, device ID); (iii) content interactions; (iv) generalized geolocation; or (v) web traffic data to understand how users access the Services and to troubleshoot technical issues. We use this data to analyze interactions with our Site and to serve you ads on the Site and on social media platforms. We collect and process this information to achieve our legitimate interests of providing and improving our Site and marketing our Services according to your stated preferences.
If you do not want us to collect or use your Personal Information in this manner, you can adjust your device settings or install a third-party plugin to prevent cookies, tags, and pixels from interacting with your device or collecting your Personal Information.
- Retention of Personal Information
Adrift retains Personal Information only as long as necessary to provide you with the Services you request. Personal Information associated with your Adrift account is retained as long as your account remains active or until you choose to delete it. We retain Personal Information associated with your reservations indefinitely. Data collected via cookies, tags, and pixels may retained for up to 26 months. Adrift may retain data, including Personal Information, for longer periods if it is critical to our business and securely stores that retained data.
- Disclosing Personal Information
Adrift will only disclose Personal Information to the third parties as described in this section, with your permission, or as required by law. In the preceding 12 months, we have disclosed identifiers, commercial information, inferences and internet or similar activity to third-party recipients for a business purpose. We may disclose this information to the following recipients:
- Service Providers. Adrift uses third-party service providers like booking platforms, payment processors, email and data hosting services, and analytics services that may have access to your Personal Information to perform their contractual obligations to us. The type of information that we disclose to a service provider will depend on the service that they provide to us. Our service providers are subject to contractual agreements that protect your Personal Information, and we require all service providers to maintain confidentiality standards that are commercially reasonable to ensure the security of your Personal Information.
- Cookie Data Recipients. Adrift permits Google and certain social media platforms to place cookies, pixels, and related technologies on your browser subject to your device settings. These technologies capture data that is transmitted back to the trusted third party so Adrift can market to you on corresponding social media channels and other platforms. You can opt-out of our use of your Personal Information in this manner by updating your device settings to control how these technologies interact with your browser.
- Affiliates. We may disclose the information we collect from you to our affiliates or subsidiaries in accordance with applicable privacy laws.
- Other Third Parties, as permitted by applicable law. For example: if we go through a business transition (e.g., merger, acquisition, or sale of a portion of our assets); to comply with a legal requirement or a court order; when we believe it is appropriate to take action regarding illegal activities or prevent fraud or harm to any person; to exercise or defend our legal claims; or for any other reason with your consent.
- Law enforcement, and other governmental agencies, at our sole discretion in connection with an investigation of any matter that is illegal or that could expose Adrift or our affiliates or subsidiaries to liability.
- Aggregated and De-Identified Information. Adrift reserves the right to disclose aggregated, anonymized, or de-identified information about any individuals with non-affiliated entities for research, product development, marketing, or other purposes, without restriction.
- Your Privacy Rights
- Controlling Your Personal Information. Adrift provides you a variety of methods and options to exercise controls over your Personal Information, such as:
- Your Adrift Account. You can review, update, correct or delete the Personal Information associated with your Adrift account at any time by logging into your account and saving your changes. If you require assistance, please contact [email protected].
- Marketing. Adrift sends marketing communications to you by email according to your stated preferences and in compliance with applicable law. You may opt-out of our marketing messages at any time by updating your account preferences, clicking the “Unsubscribe” button contained in our emails or by sending an email [email protected] with a request.
- Device Settings. You can control the data we collect through automated means by adjusting your device settings, such as blocking pop-up ads or cookies, or by installing a third-party plugin to control how cookies interact with your device.
- Do Not Track. Do Not Track signals are signals sent through a browser informing us that you do not want to be tracked. Currently, our systems do not recognize browser “do-not-track” requests, but you may disable certain tracking via your device settings.
- Your Rights Under Privacy Laws
This section offers courtesy notifications under various privacy laws, such as the European Union’s General Data Protection Regulations (“GDPR”), Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”), the California Consumer Privacy Act of 2018 (“CCPA”) and other U.S. state privacy laws and required notices to Nevada Residents regarding “sale” of personal data. Some or all of the privacy rights listed below may be available to you depending on where you reside and whether a given law governs Adrift’s business practices. NOTE THAT ADRIFT IS NOT CURRENTLY GOVERNED BY THE CCPA AND IS EXEMPT FROM CERTAIN OTHER US PRIVACY LAWS. Please contact us at [email protected] if you have questions about the specific privacy rights to which you are entitled.
- Right to access your Personal Information. You can request to access your Personal Information. Upon request, we will provide you with a copy of your Personal Information, along with details about the types of Personal Information we process, why we process it, and any third parties we work with to collect Personal Information on our behalf. We may have one or more legally valid reasons to refuse your request in whole or in part, for example in order to protect the rights of other individuals. If you are a resident of the State of California, your request is limited to specific pieces of Personal Information we have collected about you over the past 12 months, and we only have to respond to two such requests within a 12-month period.
- Right to accuracy, and the right to correct your Personal Information. If you become aware that the Personal Information that we hold about you is incorrect, or if your situation changes (e.g., change of address), please inform us and we will update our records.
- Right to data portability. In some cases, we are required to provide your Personal Information to another organization at your request and in a structured, commonly used machine-readable format, so that the other organization can read and use it.
- Right to deletion or erasure (a.k.a. the “right to be forgotten”). Upon your request, and in certain circumstances and where we are required to do so by law, we are required to delete your Personal Information. This right is not absolute, and we may be entitled to retain and process your Personal Information despite your request. If you make this request, we balance certain legal, contractual, and business interests against your right to request the deletion of your Personal Information.
- Right to restrict processing of your Personal Information. You may have the right to request that we restrict the processing of your Personal Information if (i) the data is inaccurate, (ii) the processing is unlawful, (iii) we no longer need the Personal Information, or (iv) you exercise your right to object. Your right to restrict may be limited to Personal Information that is sensitive in nature, or that is sold or shared for certain purposes.
- Right to object to certain processing of your Personal Information. You may have the right to request, under certain circumstances and where we are required to do so by law, that we will limit our processing of your Personal Information as you request.
- Right to Opt-Out of Sharing Personal Information. Adrift may share your Personal Information with third parties for cross-contextual behavioral advertising purposes using cookies and related technologies. To opt-out of this sharing, you may adjust your device settings to block cookies or install a third-party plugin to control how cookies interact with your device.
- Right to nondiscrimination. We will not discriminate against you for exercising any of your privacy rights. If you are a resident of the State of California, we will not (i) deny you goods or services, (ii) charge you different prices or rates for goods or services, (iii) provide you a different level or quality of goods or services, (iv) retaliate against you as an employee, applicant for employment, or independent contractor for exercising your privacy rights; or (v) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services, because you exercised your statutory right unless permitted by law.
- Right to disclosure of certain information about our collection and use of your Personal Information over the past 12 months. If you are a resident of the State of California, you may request that we disclose (i) the categories of Personal Information we have collected about you; (ii) the categories of sources for the Personal Information we have collected about you; (iii) our business purpose for collecting or selling that Personal Information; and (iv) the categories of third parties with whom we disclose that Personal Information. Additionally, if a business sells or shares Personal Information, the consumer may request two separate lists stating (a) sales, identifying the Personal Information categories that each category of recipient purchased; and (b) disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained. Adrift is only required to respond to two disclosure requests within a 12-month period.
- Right to disclosure of marketing information. If you are a resident of the State of California, note that California’s Shine the Light Act (Civil Code sections 1798.83-1798.84) entitles California Consumers to request certain disclosures regarding Personal Information sharing with affiliates and/or third parties for marketing purposes.
You can exercise your privacy rights to the extent they apply to you based on where you reside by sending a request to [email protected], subject to any exceptions and limitations that may apply. If you are a resident in the European Economic Area and you believe we are unlawfully processing your Personal Information, you may also have the right to complain to your local data protection supervisory authority. If you are a resident in Switzerland, you may have the right to complain to the Swiss data protection authorities.
- Submitting Privacy Requests
If you wish to exercise your rights under your applicable privacy laws beyond the methods described above, or if you want to express concerns, lodge a complaint, or request information, please send a verifiable request to [email protected]. We will verify your request, including the scope of your request under applicable laws, and respond within the legally required timeline. If we need more time to fulfill your request, we will notify you in writing of the reason and extension period. We do not charge a fee to process or respond to a verifiable request unless we have legal grounds to do so, such as requests that are excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
- International Data Transfers
Adrift is owned and operated in the United States and provides onsite hospitality services at our properties located in the United States. If you visit the Site or contact Adrift from outside of the United States, Personal Information we collect about you may be transferred out of your country of origin to our servers located in the United States or, in some cases, elsewhere in the world. Adrift is committed to using lawful data transfer mechanisms for all cross-border transfers of Personal Information. Nevertheless, when your information is moved from your home country to another country, the laws and rules that protect your Personal Information in the country to which your information is transferred may be different from those in the country in which you live. For example, if your information is in the US, it may be accessed by government authorities in accordance with US law. By submitting your Personal Information to us, you consent to the transfer and processing of your Personal Information as described in this paragraph. We do not warrant that our Services are appropriate or authorized for use in any other jurisdictions. You are solely responsible for determining whether your use of our Services complies with applicable laws.
- Data Security
Adrift employs reasonable and appropriate security procedures and practices to help protect your Personal Information from unauthorized or illegal access, destruction, use, modification, or disclosure. Adrift uses secure cloud servers to process and store all data, including your Personal Information. Access to Personal Information is limited to employees and contractors as needed to perform their job functions. We also ensure that our employees, contractors, and agents responsible for handling privacy inquiries are informed of applicable legal requirements and we restrict access to those who need that information to process it.
However, no transmission of data over the Internet is 100% secure, and we cannot guarantee that unauthorized third parties will not defeat our security measures or use your Personal Information for improper purposes. You are responsible for maintaining the confidentiality of your account username and password. We encourage you to protect against unauthorized access to your account and device by choosing a robust password and signing off after each session. Adrift is not responsible for any lost, stolen, or compromised passwords, or for any activity on your account via unauthorized activity.
- Third-party Platforms and Social Media
Adrift may provide links to or allow you to link your Adrift account to third-party social media, websites, or platforms. These features are offered as a convenience only, and Adrift is not responsible for and has no ability to control the privacy and data collection, use, and disclosure practices of any third party. When you click on links that take you to external websites or platforms, you will be subject to their privacy policies and practices and not ours. Adrift encourages you to review and understand the privacy policies of such websites or platforms before submitting any information.