Privacy Policy

August 14, 2018

Who we are

RSI International Inc. (“RSI”) appreciates your interest in its products and your visit to this website. Your privacy is important to us.

RSI is the developer of RoomKeyPMS, a cloud based hotel management system that includes eRes, an electronic booking feature. RSI provides software and services to properties around the world.

This Privacy Notice describes our global privacy practices and standards as of the date above.

Accountability

As a Canadian company based in Vancouver, British Columbia, RSI is subject to Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”) where personal information crosses provincial boundaries and international borders, the General Data Protection Regulation (“GDPR”) when personal information (“Personal Data”) is collected from data subjects in the EU, and other privacy legislation that may be applicable where RSI operates or delivers services.

RSI processes personal information on behalf of properties and also processes personal information for its own purposes, as described in detail below.

RSI’s Privacy Officer is responsible for the creation, oversight and implementation of our privacy program and procedures to protect personal information, for receiving your related questions and for providing you with information about our data protection practices.

If you have a privacy question, at any time you may contact our Privacy Officer at [email protected] or through the contact page on our website.

The personal information we collect

The data we process about you depends on who you are and how you interact with us. Personal information is information that identifies you or that makes you identifiable. It includes information that could be used to identify, locate, track, profile or contact you.

If you are a property (customer), business partner, or express interest in our services:

If you request information about our services or partnership opportunities, we process your first name, last name, email address, phone number, state or province, information about the property where you work, and any comments you provide. We append business information related to the company where you work you from third party sources, such as business intelligence providers. We also may append information from publicly available sources, such as LinkedIn.

If you enter into an agreement with us related to the licensing or purchase of our services, we process your name, email address, postal address, company name, billing information (e.g., purchase order number, bank wire information, credit card number), company size, company financial information, and signature.

If our marketing team or a member of our sales or business development teams sends communications to you, we process your name, phone number, email address, postal address, job title, job function, company name, company size, company financial information, IP address, device type, email view information including IP address and associated city, and information about which of our services you use or which may be of interest to you.

If you participate in our market research and surveys, we process your email address, job title, phone number, survey responses, company name, job function, state, country, and any comments you provide.

If you visit our website:

We process personal information about you that we collect directly, through forms or data entry fields on our website:

  • Contact us and request a demo forms – first name, last name, email address, phone number, state or province, information about the property where you work, and any comments you provide.
  • Newsletter subscription – email address.

We process personal information about you that we collect through passive collection by cookies and other data collection technologies.

  • We automatically gather standard details of your browser and operating system, the website from which you visit our website, the pages that you visit on our website, the date of your visit, and, for security reasons, e.g. to identify attacks on our website, the IP address assigned to you by your internet service provider.
  • Social plugins (“buttons”) of social networks such as Facebook, Google and Twitter are activated by default, i.e., without your intervention they can send data to the respective social networks. The social network can retrieve data, independently of whether you interact with the button or not.
    • If you are a member of a social network and do not wish it to combine data retrieved from your visit to our websites with your membership data, you must log out from the social network before visiting our website or deactivate settings in your social network site.
    • RSI does not control the data collected through these plugins. Please visit the privacy notices and practices of the social network to learn more about the rights available to you and the settings you can use to protect your privacy.
  • RSI uses cookies and similar data collection technologies to make navigation easier and increase the user-friendliness of our website. Using cookies, we track visitor preferences and identify popular sections of our website, then adapt the content of our website to improve your experience.
    • You have the right to decide whether to accept or reject cookies. You can exercise your cookie preferences by clicking on the appropriate Opt-out links provided in this cookie policy.
    • You can set or amend your web browser controls to accept or refuse cookies. If you choose to reject cookies, you may still use our website through your access to some functionality and areas of the website may be restricted. As the means by which you can refuse cookies through your web browser controls vary from browser-to-browser, you should visit your browser’s help menu for more information.
    • To find out how advertising networks offer a way to opt-out of targeted advertising: http://www.aboutads.info/choices or http://www.youronlinechoices.com
  • We also employ retargeting technology to adapt our online marketing (e.g. banner ads) on the websites of our retargeting partners (Flashtalking, Google Adwords, Google Doubleclick) more specifically to your needs and interests. This uses cookies to store details of your interest in our products and services. These cookies are read and used when you visit other websites that cooperate with our retargeting partners, to provide you with information that is as relevant as possible to your interests. The process is anonymized, i.e. you cannot be identified through retargeting.
  • Google Analytics – We use Google Analytics to complete statistical analysis. If you do not wish us to collect and analyze statistical data related to your visit, you may object to the future use of your data at any time by pressing this

 

Cookie Settings

 

If you are a job applicant, employee or contractor, or former employee

Please contact us directly at [email protected] for information about how we manage personal information processed during the hiring process and the course of managing the employee/contractor relationship.

If you are the guest of a property using RSI services

If you submit personal information directly to a property, for example over the phone in person, or online through eReswhere our services are being used to process your booking, we will only process your personal information upon the property’s instructions under contract. In this case, RSI collects information “indirectly” as a “processor” for the property, which is referred to as the “controller”.

RSI does not process the personal information you provide for a booking for its own purposes.

  • Please visit the property’s privacy notice for information about their privacy practices or contact them directly if you have questions about the personal information they have collected about you.

Where appropriate, we will assist properties in meeting their obligations related to privacy based on the legislation in their home province, state or other area. If you are a property using RSI services and would like more information, please see our support portal for Guest Privacy Services.

Your rights

You have six basic rights under the privacy and data protection laws related to the data we process about you. You may:

  1. Request access the personal information we process about you;
  2. Request that we correct inaccurate or incomplete personal information about you
  3. Request deletion of personal information about you;
  4. Request restrictions, temporarily or permanently, on our processing of some or all personal information about you;
  5. Request transfer of personal information to you or a third party where we process the data based on your consent or a contract with you, where our processing is automated; and
  6. Opt-out or object to our use of personal information about you where our use is based on your consent or our legitimate interests.

As noted above, if you have provided your personal information in the course of booking with a property using RSI services, please contact the property directly.

Where you make a request directly to RSI related to your rights under privacy and data protection laws, we will aim to respond to your request within 30 days. In some cases, there may be legal or other official reasons that we may not be able to address the specific request you make related to your rights.

Why we process personal information

The reasons that we process personal information depending on who you are and how we interact with you. RSI collects, uses and discloses personal information only for the purposes of providing our services or for other purposes to which you consent. Specifically:

  • As a data processor, we will process guest information for a property based on fulfilling the contract with the property. Each property will establish its own legal bases for processing the guest personal information.
  • We will process business information, including contact information, to fulfill a contract where you have entered into a contract or other agreement with us.
  • We will process your contact information with your consent if you request information about our services or to respond to individual rights requests.
  • We will process your contact information based on our legitimate interests in order send direct marketing communications about our services, related services or related resources.
  • We may also process personal information about you based on our legitimate interests to investigate complaints or concerns and to send optional customer satisfaction surveys.

You may withdraw your consent at any time by clicking the “unsubscribe” link in the email communications we send to you. You may also withdraw consent by exercising your rights as described above.

RSI may process information that is anonymous or de-identified to:

  • Monitor system usage, server and software performance, to improve system design, to create benchmarks and to conduct trending analyses.
  • Perform statistical analyses related to the use of the services.

Anonymous or de-identified information is the property of RSI and may be shared with third parties (e.g., partners, properties, etc.).

How we share personal information

Your personal or guest information may be shared with third parties other than other RSI only under contract and for processing as instructed by RSI, or for compliance with legal obligations as described below.

Our current list of vendors can be viewed here. Vendor List

 

Add-On Integrations

RSI offers several add-ons to RoomKeyPMS through strategic partnerships with select vendors. Depending on the nature of these integrations, guest, property or user data may be shared as part of delivering the service intended with the third party.

RSI is not responsible for how information is shared with these Partners and they are responsible for their own disclosure of privacy and data policies.

Compliance with legal obligations

We may disclose personal information to a third party if:

  • We reasonably believe that disclosure is compelled by applicable law, regulation, legal process or a government request (including to meet national security or law enforcement requirements);
  • In the enforcement of our agreements and policies;
  • To protect the security or integrity of our services and products; or
  • To protect ourselves, our other customers, or the public from harm or illegal activities.

If RSI is required to disclose any personal information as part of a legal process, we will notify, unless prohibited by law:

  • The individual the personal information is about directly, where we have collected the information directly from the individual; or
  • The property that collected the information directly from the individual.

Business transfer

If RSI enters into terms with an affiliate or subsidiary of RSI, personal information may be shared under the conditions of this Notice.

If RSI is acquired through a corporate sale, merger, reorganization, dissolution or similar event, personal information may be part of the assets transferred or shared in connection with the due diligence for any such transaction. Any acquirer or successor of RSI may continue to process data consistent with this Notice.

How long we keep personal information

We will keep personal information about you for as long as we provide services to you or as long as we are addressing a concern, question, complaint, or request you have made to us.

When you visit our website, other than the IP address, personal data is only stored if you choose to submit it to us. The IP address is stored for seven days and then deleted.

Where we have a processing contract or other agreement with a property, we will follow the retention obligations of that agreement.

We may keep data longer if we have a legal obligation to keep it or to maintain necessary records for legal, financial, compliance, or other reporting obligations, and to enforce our rights and agreements.

International transfers of personal information

We use service providers located outside of Canada to process and/or store personal information. We may transfer your personal information to jurisdictions other than the one you are in only where the recipient country or the particular person or entity receiving the data ensures an adequate level of protection for the data.

For data subjects in the EU, if we are to transfer your personal information (“Personal Data”) from the European Economic Area (“EEA”) to a recipient in the United States, we shall make sure that the recipient participates in the EU-US Privacy Shield Framework. This means the recipient has self-certified itself as ensuring a level of protection for personal information that is essentially equivalent to the one guaranteed under the GDPR.

The European Commission has formally declared that Canada’s PIPEDA ensures an adequate level of protection.

If you have any questions about this, our Privacy Officer can provide further information about our policies and practices regarding service providers and further information about how these service providers process personal information on our behalf.

Safeguards

RSI uses administrative, technical and physical safeguards to protect personal information against loss, theft, and unauthorized access, use, disclosure, copying, modification, disposal, or destruction in accordance with applicable legal requirements and industry best practices.

We ensure that only those employees responsible for our operations have physical or technical access to personal information and only where such access is required to perform work where that work is authorized by their supervisors. We train our team to follow privacy and security practices specific to our services.

We also have implemented measures to maintain the ongoing confidentiality, integrity and availability of the systems and services that process personal information and will restore the availability and access to data in a timely manner in the event of a physical or technical incident.

We will review and update our security policies and controls as technology changes to ensure ongoing personal information security, however please bear in mind that no Internet or email transmission is ever fully secure or error free and no security system is impenetrable. We cannot fully guarantee the confidentiality of any information that you share with us.

It’s important to guard your privacy when you are online. If our services contain links to other websites, this Privacy Notice does not govern those websites. Whether we have posted those links or other organizations or individuals have, you should read their privacy policies and make an informed decision about whether you want to use those websites or their services.

Openness

RSI makes clear and transparent notice of our privacy practices publicly available via this Privacy Notice.

We are obligated to inform properties in the event of an incident where their guests’ personal information is lost, stolen, accessed, used, disclosed, copied, modified, or disposed of by unauthorized persons or in an unauthorized manner.

Where we have collected personal information from you directly, we will advise you at the first reasonable opportunity upon discovering or being advised of an incident where your personal information is lost, stolen, accessed, used, disclosed, copied, modified, or disposed of by unauthorized persons or in an unauthorized manner.

Changes to this Privacy Notice

We may update this Notice to reflect changes to our information practices but we will not reduce your rights under this Privacy Notice without your explicit consent. We’ll post any changes to this page and, if the changes are significant, we will provide a more prominent notice (including email notification of privacy notice changes for certain services). We’ll also keep prior versions of this Privacy Notice in an archive for your review.

We encourage you to periodically review our Privacy Notice for the latest information on our privacy practices and to contact us if you have any questions or concerns.

Challenging compliance and lodging complaints

RSI’s Privacy Officer is responsible for receiving your privacy-related questions. You may send your questions or challenge our compliance with our Privacy Notice by submitting your concern to:

Privacy Officer

RSI International Inc.
Unit 8152

200-375 Water Street

Vancouver BC, V6B 0M9
Tel: 604.984.600
Toll free: 800.234.5695

If you have concerns about how we handle your personal information, you have the right to lodge a complaint with a supervisory authority in the EU or the Office of the Privacy Commissioner of Canada.

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