Publish Date: November 17th, 2021
Publish Date: November 17th, 2021
Please read this Privacy Policy ("Policy") carefully before using the Services. RV Friend Network, LLC ( “RVillage,” “we,” “our,” or “us”) (an affiliate of TH2connect, LLC d/b/a Roadpass Digital) respects your privacy and is committed to protecting it through our compliance with this Policy. This Policy explains how we collect, process, use, store and disclose your Personal Data, as well as your rights associated with that data. RVillage operates in countries with differing requirements for data protection. This Policy is written for the broadest application to RVillage’s practices. Specific differences for California (US) will be highlighted in the section on “Your Rights.”
Please also use the Glossary at the end of the document to understand the meaning of some of the terms used.
We strive to enhance the RV experience by providing services and technologies that foster community development through building social connections, the peer to peer exchange of RV knowledge, and by offering virtual and in person events for members. We respect your privacy, and we believe you should be informed about what Personal Data we may collect when you interact with us.
This Privacy Policy applies to Personal Data collected by us unless an exception applies. This Policy tells you about what information we may collect and how we may process, share, and use it. Please read this Policy carefully.
When we reference our “Service” or “Services”, we mean technologies, capabilities, features, applications, websites, social media pages which reference this Policy, and other products and services, and communication channels we may provide (including but not limited to the RVillage website and mobile application).
This Policy does not apply to: (a) any services that have a separate privacy policy which does not incorporate this Policy; or (b) third-party cookies, products or services (including websites, mobile applications, platform features, app stores, and applications), all of which are governed by their own respective privacy policies (even if our Services contain them, use them, or link to them). We are not responsible for third-party privacy practices.
Note: You have a choice as to whether you want to share Personal Data with us. If you choose not to provide us with certain information, we may not be able to offer you certain Services, you may not be able to access certain features of our Services, or our Services may not function properly or at all.
Basic Principles. The Policy adheres to the GAPP privacy principles, based on internationally known fair information practices, included in many privacy laws and regulations under which RVillage or its parent companies may operate. The GAPP principles are as follows:
| Principle | Description |
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| Management | RVillage will define, document, communicate, and assign accountability for its privacy policies and procedures. |
| Notice | RVillage will provide individuals with required notice in a timely manner where required and identify the purposes for which Personal Data is controlled or Processed. |
| Choice and consent | RVillage will provide individuals with any required choices regarding the Processing of their Personal Data. |
| Collection | RVillage will collect Personal Data only for legitimate business purposes. |
| Use, retention, and disposal (Purpose Limitation) | RVillage will limit the use of Personal Data to the purposes identified in the notice and for which the individual has provided implicit or explicit consent, as required by law. RVillage will only retain Personal Data for as long as necessary to fulfill the stated purposes as required by law or regulation and thereafter appropriately dispose of such Personal Data. |
| Access | RVillage will provide a mechanism to allow individuals to access and correct their Personal Data, when required by applicable regulation. |
| Disclosure to third parties (Onward Transfers) | RVillage will disclose Personal Data to third parties only for the purposes identified in the notice and with the implicit or explicit consent of the individual in accordance with regulatory requirements. |
| Safeguarding (Security) | When Processing Personal Data, RVillage will protect it from unauthorized access (both logical and physical). |
| Quality (Data Integrity) | RVillage will maintain accurate, complete, and relevant Personal Data for the purposes identified in the notice. |
| Monitoring and enforcement | RVillage will monitor compliance with its privacy policies and procedures and have procedures to address privacy-related complaints and disputes. |
Types of Personal Data. This Policy applies to information we collect. We may collect, use, store and transfer different kinds of Personal Data about you, which we have grouped together as follows:
We also collect, use and share aggregated data such as statistical or demographic data, which may be derived from your Personal Data but is not Personal Data as it does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature of our Services. However, if we combine or connect aggregated data with your Personal Data so that it can directly or indirectly identify you, we treat that combined data as Personal Data which will be used in accordance with this Policy.
Sensitive Data. We do not collect any Sensitive Data about you (such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) unless you make such information publicly available by including it in your public profile. We also do not collect any information about criminal convictions and offences.
Children under the Age 18. Our Services are designed to enhance the travel experience. We do not market our Services towards consumers under the age of 18. We do not knowingly collect Personal Data from children under 18 years of age. No one under age 18 may provide any information to or on our Services. If you are under 18, do not use or provide any information through our Services or their respective features. If we learn we have collected or received Personal Data from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us. Any sale of user Personal Data does not include information about individuals we know are under 18 years of age.
Consent to Policy. Refusal to provide your Personal Data: Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Services. By accessing or using our Services, you agree to this Policy. You do not have to provide your Personal Data when we request it, but if you choose not to, we may not be able to respond to your queries and perform any contract we have or are trying to enter into with you. That may mean we have to cancel a Service you have with us. We will notify you at the time if that is the case.
We use different methods to collect Personal Data from and about you including through:
Direct Interactions. You may give us your Identity, Contact, Profile, Financial, and other data by filling in forms on our Services, on third-party websites, applications, or services, or in paper form or by corresponding with us by post, phone, email or otherwise. That includes Personal Data you provide when you:
Automated Technologies or Interactions. As you interact with our Services, we may automatically collect Technical and Usage Data about your equipment, browsing actions and patterns, including:
We collect this Personal Data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. We may combine Technical Data (some of which will be anonymous) with other Personal Data we have collected from you in order to understand and measure your online experiences and determine what products, promotions and services are likely to be of most interest to you.
The technologies we use for this automatic data collection may include:
We may tie automatically collected information to Personal Data about you that we collect from other sources or you provide to us.
Third Parties or Publicly Available Sources. We may receive Personal Data about you from various third parties including our affiliates, customers, business partners, and certain public and technical sources:
Third-Party Use of Cookies and Other Tracking Technologies. Some content or applications, including advertisements, on our Services are served by or integrated with third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Services. The information they collect may be associated with your Personal Data or they may collect information, including Personal Data, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. The marketing and analytics services that integrate directly into our Services include Google Analytics.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see the “Choices About How We Use and Disclose Your Information” section of this Policy.
Third Party Links. The Services may contain links to other websites or applications (“Linked Sites”) that are not owned by us. We do not control the collection or use of any information, including Personal Data, which occurs while you visit Linked Sites. Therefore, we make no representations or warranties for —and will not in any way be liable for—any content, products, services, software, or other materials available on Linked Sites, even if one or more pages of the Linked Site are framed within a page of the Services. Furthermore, we make no representations or warranties about the privacy policies or practices of the Linked Sites, and we are not responsible for the privacy practices of those Linked Sites. We encourage you to be aware of when you leave the Services and read the privacy policies of Linked Sites.
Unsolicited Personal Data. If we receive Personal Data that we have taken no active steps to collect (such as a job application sent to us by an individual on their own initiative, rather than in response to an advertisement), then we may keep that Personal Data if it is reasonably necessary for one or more of our functions or activities. We will destroy it or ensure it is de-identified, provided it is lawful and reasonable to do so.
| Purpose/Activity | Type of data | Lawful basis for processing |
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| New customers: To provide, administer, protect, and enhance our Services, to enhance user experiences, and to develop new services |
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Performance of a contract with you |
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Provide services: To provide our Services to you, including: register your account(s) and purchased subscriptions and Services, and to provide customer support (including assisting you with your account and solving other problems you may experience) respond to your inquiries, to help you solve problems you may be experiencing, and provide support regarding your account and our Services |
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Relationship management: To manage our relationship including: inform you about changes or enhancements to our Services and changes to our Services, terms of use, and policies asking you to leave a review or take a survey keeping you up to date with our latest news |
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Improve Services: To constantly improve our Services, tailor them to your needs, develop new Service ideas and inform you of any changes to our Services To conduct and facilitate market research (including surveys, data analytics, market research, financial analysis, and customer segmentation) To engage in ad retargeting and evaluation of the effectiveness of marketing efforts |
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Promotions/ Advertisements: To communicate about, promote, and administer our Services, events, programs, and promotions (including sending marketing communications, promotional materials, notices, alerts, newsletters and conducting sweepstakes and contests) |
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Technical maintenance: To administer and protect our business, content, websites and mobile apps including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data and monitoring for unauthorized use To maintain and promote the safety and security of our Services, our IT network, and our employees |
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Data analytics: To perform data analysis to: improve and personalize your experience on our platforms improve our Services, marketing, customer relationships and experiences |
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Necessary for our legitimate interests (to define types of customers for our Services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
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Promote our Services: To provide you with information and ads about third party offers, merchants, attractions, locations, and Services which may be nearby or which otherwise may be of interest to you To conduct marketing and sales activities (including lead generation, pursuit of marketing prospects, market research, managing and evaluating the effectiveness of advertising and marketing efforts, and managing our brands) |
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Necessary for our legitimate interests (to develop our Services and grow our business) |
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Safety and security: To verify your identity and to protect against unauthorized transactions, fraud, and other unlawful activity, claims and other liabilities, and to manage risk exposure and quality. This may include criminal background checks or other screenings. We may also use technologies such as Google Cloud Vision API SafeSearch Detection to detect and remove explicit content on the Services. |
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Other: To carry out our obligations and enforce our rights arising from any contracts entered into between you and us (including for billing and collection); to conduct investigations; to comply with and enforce applicable legal obligations, relevant industry standards, other contractual obligations, and our terms, policies and procedures; to fulfill any other purpose for which you provide it or for which you give consent. |
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We aim to provide you with choices about how your Personal Data is used for marketing and advertising purposes.
You will only receive marketing communications (including newsletters and information about our own and third-parties’ goods and services that may be of interest to you) from us if you have opted in or consented to receiving those communications. We may use your Personal Data collected in those circumstances to contact you and keep you up to date with the latest news, events, special offers and promotions of our brands, including by email, text messages, or push notifications.
We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. This may include email communications, push notifications, and AWS notifications. If you do not want us to use your information in this way, please follow the instructions in the “Choices About How We Use and Disclose Your Information” section of this Policy under “Promotional Offers from us.”
You can update your subscription preferences or unsubscribe from marketing communications at any time by following the update preferences or unsubscribe instructions provided in each such communication, or alternatively by contacting us at support@rvillage.com Please be aware that although you may opt-out of update messages and/or direct marketing communications, we reserve the right to email you administrative notices regarding the Services, as permitted under the CAN-SPAM Act.
We may display advertising for you to see on third-party websites, including social media sites such as Facebook. We do this by matching information about your activity on RVillage’s Services with information collected on third-party sites or services. That may involve using your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you.
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider we need to use it for another reason compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at the contact information provided below.
If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may share your Personal Data with the following parties for the purposes set out in the table in Section 5 above or for other purposes directly related to the purpose for which the information was collected.
Affiliates. When consistent with the purposes set forth in this Policy, we may share Personal Data with affiliates, including entities within the Roadpass Digital group of companies (including TH2connect, LLC d/b/a Roadpass Digital, Togo Tech, LLC, Roadtrippers LLC, Togo RV, and Campendium, Inc.) and their divisons (including Togo RV and Overnight RV Parking) when consistent with the purposes set forth in this Policy. The other affiliates (and their divisions) that make up the Roadpass Digital group of companies are contractually bound to keep Personal Data confidential, to maintain adequate safeguards, and use it only for the purposes for which we disclose it to them or to comply with legal requirements.
Service Providers (Data Processors). We may also share Personal Data with contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Data confidential and use it only for the purposes for which we disclose it to them, providing services on our behalf, including:
Merger or Acquisition. We may also share Personal Data with other third parties in the following circumstances:
Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners or newly associated companies may use your Personal Data in the same way as set out in this Policy:
Law Enforcement, Safety and Legal Processes. We may also disclose your Personal Data:
We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.
We strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with the following control over your information:
We process your Personal Data primarily in the United States. Therefore, we may transfer your Personal Data outside of the country where you live to the United States. If we transfer your Personal Data outside of the country where you live, we will take all reasonable steps to ensure the Personal Data we transfer is secured by an adequate level of data protection during and after your Personal Data is transferred.
Depending on your jurisdiction, you may have the following rights in relation to your Personal Data.
11.1 Your California Privacy Rights (Applicable to California Residents)
11.1.1 California Civil Code Section § 1798.110: Access
Because we collect consumer information, a California consumer can request the following from us in a portable, readily usable format that allows you to transmit your information to another entity without hindrance:
11.1.2 California Civil Code Section § 1798.115: Access
Because we disclose and sell consumer information to 3rd Parties, a California consumer can request that we disclose:
11.1.3 California Civil Code Section § 1798.105: Deletion
Because we collect consumer information, a California consumer can request that we delete any Personal Data we have collected about them to the extent permitted by applicable laws or regulations. This right is referred to as the right to deletion.
11.1.4 California Civil Code Section § 1798.120: Opt-Out
The California consumer can direct us not to sell the consumer’s Personal Data. This right is referred to as the right to opt-out.
11.1.5 California Civil Code Section § 1798.125: Non-Discrimination
We will not discriminate against a consumer because the consumer exercised any of their consumer’s rights.
11.1.6 California Civil Code Section § 1798.130: Submitting Requests
We provide the following methods for making these requests:
We have implemented measures designed to secure your Personal Data from accidental
loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. All Financial Data is handled directly by our third-party PCI-certified payment providers, Stripe and PayPal (and any information you provide to them is governed by their privacy policy). Your Financial Data is encrypted and transmitted directly and securely to Stripe or PayPal via HTTPS, and is not stored on our systems.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to or from our Services. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures provided in connection with any of our Services.
In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your Personal Data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.
To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means and the applicable legal requirements.
Data Protection Officer. We have appointed a data protection officer (DPO) who is responsible for overseeing privacy issues for RVillage. If you have any questions or complaints about this Policy, including any requests to exercise your rights in relation to your Personal Data, please contact the DPO using the details set out below.
Name: Chris Lane
Email address: privacy@roadpass.com
Postal Address: 601 E Beardsley Ave, Elkhart, IN 46514
Your concerns will be addressed promptly, in a manner consistent with our Privacy Principles.
We reserve the right to update and change this Policy at any time by posting changes on this webpage, applicable mobile apps or via other channels that we think are suitable. The date this Policy was last revised is identified at the top of the page.
You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting this Policy on the applicable Service to check for any changes. Please keep us informed if your Personal Data changes during your relationship with us.
Your continued use of our Services after we make changes is deemed to be acceptance of those changes, so please check this Policy periodically for updates.
Comply with a legal or regulatory obligation means processing your Personal Data where that is necessary for compliance with one or more of our legal or regulatory obligations.
Data Controller means whomever determines the purposes and means of processing Personal Data.
Legitimate Interest means our interests in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Performance of Contract means processing your data where that is necessary under a contract with you or to take steps at your request before entering into such a contract.
Personal Data means any information about an individual that can be used to identify that person directly or indirectly by reference to a range of identifiers. It does not include anonymous data where the identity of the individual has been removed.
Processing means any operation or set of operations performed on Personal Data.
Processor means the entity that processes Personal Data on behalf of the controller.
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