Privacy

Thank you for using Cozrum!
This Privacy Policy describes how Cozrum Vacation Rental Management , Inc. (“Cozrum”, “we”, “us” or “our”) collects, uses, processes and shares your information, including personal information, that we collect from visitors to the Cozrum website, including any subdomains thereof, and any other websites through which Cozrum makes its services and information about its services available on any type of device (collectively, the "Website"). This Privacy Policy also describes what choices you have in managing your personal information. We very much appreciate your using Cozrum and understand the importance of your personal privacy. This Privacy Policy is designed to provide consumers ("you" or "your"), who use our Website, with tools to help understand and control the collection, use, and sharing of that personal information. Cozrum reserves the right, at any time, to modify this Privacy Policy. If we make revisions that change the way we collect, use, or share personal information, we will post those changes in this Privacy Policy. You should review this Privacy Policy periodically so that you keep up to date on our most current policies and practices. We will note the effective date of the latest version of our Privacy Policy at the end of this Privacy Policy.

The Types of Information We Collect

For the purpose of this Privacy Policy, when we use the term "personal information" we mean information that is connected to your name. For individuals who become a registered user of the Website or otherwise transact on the Website, this will include information such as email address, telephone number, home address, and zip code. Personal information may also include information you provide to us including: credit card information, your birthday, transaction history, home value, home location, company information, job title, and information about your traveling companions. Other information we collect may include marketing information, including both offline and online information, such as:
• Behavioral or demographic attributes, when tied to personal information.
• Transactional data based on past purchase behavior, when tied to personal information.
• Data from marketing opt-in lists, consumer surveys, or publicly available information.
• Unique IDs such as a cookie placed on a computer, mobile or device IDs.
• Internet Protocol address ("IP address") and information derived from IP address such as geographic location.
• Information about a device such as information contained in HTTP headers or other internet transfer protocol signals, browser or device type and version, operating system, user-agent strings and information about or from the presence or use of "apps" on mobile devices.
• Demographic information such as a consumer's gender, age, and income range, when not tied to personal information.
• Behavioral data of consumers' computer or device usage on websites or apps, such as advertisements clicked, websites and content areas, date and time of activities.
• The web search a consumer used to locate and navigate to a website.
• Latitude/Longitude data.

How We Collect Information

We may collect information from you in the following ways:
By Asking. We may collect some personal information from you by asking that you provide it to us. For instance, when you register on the Website, join Cozrum as a home owner, join Cozrum’s partner network or book travel online. Cookies. Many sites use "cookies," which are small text files that reside on your computer to identify you as a unique user. We may use cookies on the Website to allow us to, among other things, measure activity and to personalize your experience. For instance, cookies may enable us to remember your viewing preferences without requiring you to re-type a user name and password. Cookies may also allow us to track your status or progress when requesting products, services, or information. If you choose, you can set your browser to reject cookies or you can manually delete individual or all of the cookies on your computer by following your browser's help file directions. However, if your browser is set to reject cookies or you manually delete cookies, you may have some trouble accessing and using some of the pages and features that are currently on the Website, or that we may put on the Website in the future.
Web Beacons. A web beacon is an electronic file on a web page that allows us to count and recognize users who have visited that page. Among other things, a web beacon can be used in HTML-formatted email to determine responses to our communications and measure their effectiveness, for instance, if you get an email from us and click on a link in that email to go to the Website. You can generally avoid web beacons in email by turning off HTML display and displaying only the text portion of your email. Web Server Logs. Web server logs are records of activity created by the computer that delivers the webpages you request to your browser. For example, a web server log may record the search term you entered or the link you clicked to bring you the webpage. The web server log also may record information about your browser, such as your IP address and the cookies set on your web browser by the server. Geo-Location Technologies. We may collect information about the location of your device if you provide your consent. You may request at any time that we do not collect information about your location by contacting us at the address listed below under the Section titled “How We Communicate With You.” Social Networking Sites. If you log into your user account through shared sign-in services (e.g., Facebook Connect), you provide Cozrum with permission to access certain information about you from that social networking site, such as your user profile, friend list, and profile picture. Enhanced Information. We also may enhance the personal information we collect from visitors with other information from third party Data Sources, as defined below.
Third Party Data Sources. We may receive marketing information from third parties, such as our vendors, commercial partners, data providers, and data partners ("Data Sources"). We allow Data Sources to send us marketing information that they have collected from both online and offline sources. This may include information from customer lists, website memberships, or other information created from a third-party's own technology (such as proprietary modeling or matching technology of other companies).

How We Use Information

Our primary purpose in collecting personal information from our visitors is to provide visitors with products, services, and information that we think may be of interest. For example, we use your personal information to:
• Complete or process transactions for you and send you confirmations and receipts.
• Fulfill booking requests you have made and assist in your travel planning.
• Provide you with information regarding your vacation rental home and its booking transactions or potential booking performance.
• Recognize you when you return to the Website.
• Tell you about updates to your account, products, and services.
• Answer questions and respond to your customer service requests.
• Monitor the usage and performance of the Website, and determine aggregate information and usage patterns.
• Make the Website easier to use, help diagnose problems with the Website, or enhance the Website for optimal user experience.

Website, or enhance the Website for optimal user experience.
We may use your personal information to advertise and market our products and services (and those of our partners) to you, for example, to present targeted advertisements on the Website and other third party web sites, in email marketing, and in direct mail marketing. We also use your personal information to analyze the effectiveness of our advertisements, and to determine whether you would be interested in new products or services we may offer.

How We Share Information

We may share information about you with third parties in certain circumstances including in the following situations:
Sharing Your Information with Service Providers. We may share information with third-party service providers in order for those service providers to perform business functions for Cozrum, and help us to fulfill our and/or our home owner’s contractual obligations on a booking transaction, e.g., arranging housekeeping services. Service Providers also help us to create or maintain our databases, research and analyze the people who request products, services or information from us, to prepare and distribute communications, or to respond to inquiries.
Law Enforcement and Legal Process. We may report to law enforcement agencies any activities that we reasonably believe to be unlawful, or that we reasonably believe may aid a law enforcement investigation into unlawful activity, as well as disclose your information to the extent required by a valid order of a court or other governmental body or by applicable law. In addition, we reserve the right to release your information to law enforcement agencies if we determine, in our sole judgment, that either you have violated our policies, or the release of your information may protect the rights, property, or safety of Cozrum, or another person.
Sharing Your Information as Permitted by Law. We may share your information with others as required by, or permitted by, law. This may include sharing your information with governmental entities, or third parties in response to subpoenas, court orders, other legal process, or as we believe is necessary to exercise our legal rights, to defend against legal claims that have been brought against us, or to defend against possible legal claims that we determine in our sole discretion might be brought against us.
Business Transition. In the event that we, or any portion of our assets, are acquired or we undergo another transition in our business, your information may be transferred to the acquiring company or other entity surviving such a transition.
Behavioral Advertisers. We may participate in behavioral-based advertising. This means that a third party may use technology, such as a cookie or a web beacon, to identify you on the Website so that they can provide advertising about products and services tailored to your interest. That advertising may appear either on the Website, or on other web sites.
Marketing Initiative. We may disclose personal information or other marketing information to our third-party service partners for executing offline and online marketing campaigns. We may use third-party service providers, acting on our behalf, to create and display advertising or other content. This information is used to personalize our communications with you about products and services that are specific to your needs and interests. Rather than burden you with information that is not relevant or of interest to you, we try to target information that is specifically important to you.
Partner Companies. We may share your personal information with carefully selected outside companies when we believe their products or services may interest you. If you do not want your personal information shared in this manner, please contact us at the address listed below under the Section titled “How We Communicate With You.”
Blogs, Online Postings, and Testimonials. We may decide to allow visitors to share comments, postings, testimonials, or other information. If you choose to submit such information to us, the information that you submit may be available generally to the public. Information you provide in these areas may be read, collected, and used by others who access them.

How We Secure Personal Information

We take reasonable and appropriate measures to help keep information secure, and to help prevent it from becoming disclosed to individuals who are not described in this Privacy Policy. While we follow reasonable procedures to try to protect the information in our possession, no security system is perfect and we cannot promise, and you should not expect, that your personal information will remain secure in all circumstances.

Limiting The Way We Share Your Personal Information

Data Access and Portability. In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).
Data Retention and Erasure. We generally retain your personal information for as long as is necessary for the performance of the contracts between you and us, to fulfill your requests as a customer or potential customer, and to comply with our legal obligations. If you no longer want us to use your information, you can request that we erase it by contacting us at admin@cozrum.com. Please note that if you request the erasure of your personal information:
• We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, Cozrum may keep some of your information for tax, legal reporting and auditing obligations.
• We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend an Cozrum user for fraud or safety reasons, we may retain certain information from that user to prevent that user from using Cozrum in the future.
• Information you have shared with others (e.g., property reviews) may continue to be publicly visible on the Website. Additionally, some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers.
• Because we maintain the Website to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.
Withdrawing Consent and Restriction of Processing. Where you have provided your consent to the processing of your personal information by Cozrum, you may withdraw such consent at any time by sending a communication to Cozrum specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defense of legal claims; or (iv) verification is pending as to whether Cozrum’s legitimate interests in processing your information override your own.
Opting Out of Email Communication. If you decide that you do not want to receive commercial emails from us, you can "opt-out" from receiving such emails by clicking on the "unsubscribe" link provided at the bottom of every commercial email. Please note that if you choose to opt-out, we will still send you email relating to specific products or services that you purchase, or email that we believe is pertinent to any communication that you have sent to us, or relationship that you may have with us. If you decide at a later time that you would like to receive commercial emails from us, you can re-add yourself to our communication list.

How We Communicate With You

If you have any questions or concerns regarding this Privacy Policy, or if you would like to opt-out or unsubscribe from our use of your personal information, you may reach us by email at: admin@cozrum.com (Attn: Privacy).
If we need, or are required, to contact you concerning any event that involves your personal information we may do so by email, telephone, or mail.

Miscellaneous

Shared Accounts. If you limit your privacy settings on an account that you hold jointly with someone else, your privacy choices will apply to everyone on your account.
Children. We do not intentionally collect information from, and do not tailor any marketing efforts to, children under 18 years of age.
Other Websites. The Website, our emails, or our application may link to third parties' websites. It is also possible that third parties' websites or emails may link to the Website. We are not responsible for the content or the privacy practices employed by third parties, and information collected by third parties is not governed by this Privacy Policy. We encourage you to read the privacy policies of these websites before transmitting any personal identifiable information to third parties. Information collected by the third party is not governed by this Privacy Policy.
International Operations. Cozrum is based, and the Website is hosted, in the Vietnam. If you are from a country outside of the Vietnam with laws governing data collection, use, and sharing that may differ from VN law and you provide personal information with us, please note that any personal information that you provide to Cozrum may be transferred to the Vietnam. By providing your personal information, you hereby specifically and expressly consent to such transfer and processing and the collection, use, and sharing set forth in this Privacy Policy or in any terms of use related to the use of and access to the Website.

EFFECTIVE DATE: 5/06/2021