The LUSSO Collection Privacy Policy

Policy Adoption Date: January 1, 2006
Last Updated: June 1, 2006

This privacy policy ("Privacy Policy") covers the treatment of personally identifiable information collected by or submitted to VREP, LLP, a Minnesota limited liability limited partnership which does business under the trade name THE LUSSO COLLECTION ("we," "us," or "our") via the Internet, by telephone, by mail or otherwise. Please review this Privacy Policy carefully.

Please note that to the extent that this Privacy Policy is inconsistent with applicable law or regulations, or to the extent you provide your express consent for uses not specifically described below, then such laws or regulations, or your express consent, will govern our use of your personal information.

INFORMATION COLLECTION

General

We collect personally identifiable information that you provide to us over the Internet (via our websites, generally located within our addresses under the domain www.LUSSOCOLLECTION.com (our "Sites")), by email, by regular mail, by phone, and personally identifiable information legally provided to us by third parties. The personally identifiable information that we may collect includes your name, physical address, email address, phone numbers, date of birth, personal interests, information regarding your interest and use of our services, your occupation, background information relevant to your applications (if you submit any) and other information relevant to responding to your inquiries and providing services to our members and business partners. If you are a member or prospective member, we may also collect personal information about you or your family (e.g., names and ages of family members, travel preferences, etc.) that will help us provide a more complete membership experience (e.g., arranging proper accommodations, responding to meal requests, etc.). If you are a member, we may collect financial information from you, such as credit card numbers, billing addresses, expiration dates, and etc., in order to facilitate the billing and payment of your accounts.

For information that we request from you, we attempt to notify you which categories of information are required and which are optional. If you do not wish to provide us information that we request, then you should not provide such information. However, please be aware that if you do not provide us with certain information that we require, then we may not be able to respond to your requests, process your applications, bill or pay you in accordance with your proposed contracts with us, or provide you complete services. If you have any concerns about the nature of the information please contact us.

Certain Forms of Information Collected on the Internet

Use Data

If you use our Sites, we may collect non-personally identifiable information about your use of the Sites (such as IP addresses, domains, browser type and version, and operating system) ("Use Data").

Cookies

A cookie is a small file stored on a user's computer that contains information about the user. We may use either session ID cookies and/or persistent cookies. For the session ID cookie, once a user closes the browser, the cookie simply terminates. A persistent cookie is a small text file stored on a user's hard drive for an extended period of time. Persistent cookies can be removed by following Internet browser help file directions. By showing how and when you use our Sites, cookies help us see which areas are popular and which are not and help in targeting information based on your interests. Cookies also allow us to store the personal preferences that you set during each visit to our Sites, which in turn allows us to speed up your future activities at our Sites. Most browsers are initially set to accept cookies. You can set your browser to notify you when you have received a cookie, giving you the opportunity to decide whether to accept it. You have the option to reject our cookies and still use our Sites, but you may not be able to access or use some of the features we offer on our Sites (including certain members-only functions and functions with respect to our referral programs).

Log Files

Like most standard website servers, we use log files. This includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks.

Clear GIFs

We may employ software technology called clear GIFs (sometimes referred to as Web Beacons or Web Bugs), which help us better manage content on our Sites. Clear GIFs are tiny graphics with unique identifiers, similar in function to cookies, and are used to track the online movements of users. The main difference between the two is that clear GIFs are invisible on the page and are much smaller, about the size of the period at the end of this sentence. We may also use clear GIFs in our HTML-based emails to let us know which emails have been opened by the recipients.

USE OF INFORMATION

Use to Fulfill Our Obligations and Your Requests

We will use your information to provide you with any information that you request from us and to address any communication that you may have initiated or authorized.

We will also use your information to fulfill our obligations to you pursuant to any contracts or agreements that you may enter into with us, and in connection with any of our programs, events or promotions for which you register or in which you participate. For example, if you are a prospective member, we use information you submit in connection with your application to process your application (which may include a background check), establish your account and activate your membership. If you are a member, we use your information to provide you services and administer your account, including as necessary to make arrangements for stays at our properties and to bill you for amounts that you owe us. If you are a participant in one of our sales or marketing programs, we will send you information relevant to your participation, such as marketing materials or announcements about upcoming events related to the program.

We may also use your information to provide assistance or support with respect to your use of our services or Sites, to troubleshoot problems and to resolve disputes that may arise. Further, we may use your information to improve our content, advertising or services, or to analyze trends or to customize the display or format of our marketing content or Sites.

We will not use your information or send you information if you have notified us of your preference not to have your information so used, or not to receive such information, or when we are prohibited by law from doing so.

Sharing of Information

To the extent permitted by applicable law and regulations, we may share your information with the following types of persons:

  • Third parties that perform information processing on our behalf, such as companies that manage our membership-wide emails, that conduct surveys for member satisfaction, that perform background checks, that help us send information regarding companies, products or services in which we believe you may be interested, or that provide analyses of use of our services or Sites.
  • Third parties that perform on our behalf, or that help us perform, our contractual obligations to you.
  • Our corporate affiliates and other entities that operate websites for us
  • In response to a request by law enforcement or other governmental personnel or court order or subpoena; if we are under a legal obligation to do so; to protect the integrity of our company if we believe that a user has committed unlawful or otherwise harmful acts; to protect our interests in connection with a legal proceeding; in emergency situations to protect health or safety; if we believe such disclosure is in your vital interest; or if we obtained your information from public sources.
  • In connection with any merger or consolidation with, or sale of substantially all of our assets to, an affiliated entity or third party, provided that such party agrees to comply with our Privacy Policy or you are given a choice if such party would like to use such information in a manner materially different from that disclosed in our Privacy Policy.

Use Data

We use aggregated (i.e., non-personally identifiable) Use Data for purposes of site administration and to compile information about usage of our Sites and services. We may share aggregated information (which does not contain your personally identifiable information) with third parties, such as advertisers and marketing partners.

We may combine personally identifiable information with Use Data to help us serve you better in connection with your use of our services or Sites, and to respond to your requests for technical assistance (e.g., we may record which web browser you use in order to help respond to your questions with difficulties using our Sites).

Security

We have taken appropriate technical and organizational measures to help prevent unauthorized access, maintain data security, and to make proper use of the information that we collect. However, no transmission of data over the Internet is guaranteed to be completely secure and we cannot guarantee the security of any information you provide to us. For example, third parties may unlawfully intercept or access transmissions or private communications. Therefore, although we use industry standard practices to protect your privacy, we do not promise or guarantee, and you should not expect, that your personally identifiable information or communications with us will always remain private.

MODIFYING OR DELETING PERSONAL INFORMATION

We intend to keep your information accurate and up to date. You have the opportunity to review and correct any of your information that we may have, or to restrict the uses we make of your information.

In order to review or correct your information that we have on file, please take the following steps:

  • Contact us via email at info@lussocollection.com
  • Give us your name and email address, together with any information that might help us more effectively serve or communicate with you
  • Let us know how we can help you - if you would like to review your information, etc.
  • Let us know the most convenient way for us to communicate with you (email, phone, etc.)

If you request that certain information be amended, we will use reasonable efforts to accommodate your request in a timely manner. If you are a member or otherwise have established a contractual relationship with us, there is certain information that we must maintain in order to properly service your account. We retain certain information in our sole discretion that we need to process your information in order to fulfill your requests and our contracts with you, to maintain our records in accordance with industry practices, to resolve disputes, to troubleshoot problems, to enforce this Privacy Policy, or for other valid business reasons; it is not our policy to retain more information for longer than is necessary. Please note that we will not remove your non-personally identifiable Use Data from our aggregated files. Furthermore, please be aware that even if you request that your information be removed from our systems, such information may never be completely removed due to technical and legal constraints, including backup and disaster recovery systems, as well as the need to keep some information to track and record your requests.

NOTIFICATION OF CHANGES TO THIS PRIVACY POLICY

We may, in our sole discretion, revise this Privacy Policy at any time and in any manner (subject to compliance with applicable law and regulations). When we revise this Privacy Policy, will revise the "last updated" date at the top of this web page. Please check this Privacy Policy periodically for its most current version and to confirm your continued agreement with its terms, which will be inferred by your continued association with us following any such modifications.

MINORS

Our Sites and services are not directed toward persons under eighteen years of age and we do not knowingly collect information from people under the age of eighteen.

LINKS

Our Sites may contain links to other sites. Please be aware that we are not responsible for the privacy practices of such other sites or their operators. We encourage our users to be aware when they leave our Site and to read the privacy statements of each and every website that collects personally identifiable information.

CONTACT US

If you have any questions or comments regarding our Privacy Policy, please contact us at the address, phone number, or email listed below:

The LUSSO Collection
6001 Shady Oak Road
Suite 250
Minnetonka, MN 55343
1-866-GO-LUSSO
info@lussocollection.com

If you have any technical questions or comments regarding the website itself, you may direct your inquiries to webmaster@lussocollection.com.