Effective Date: May 25, 2018

About ChannelRUSH

ChannelRUSH is a software company that creates products and services for businesses in the hospitality industry. Customers of ChannelRUSH include, but are not limited to, hotels, resorts, timeshares, rental properties, and hospitality management companies. We also work with the companies our customers work with to process lodging reservation information.


Getting Oriented

ChannelRUSH processes two broad categories of personal information when you use our products and services.

  • Direct Customer Data
    Your personal information as a customer of ChannelRUSH.
  • Indirect Customer Data
    The personal information of your end customers (i.e. those who book reservations at your property, or those who book reservations at properties overseen by your management company).

ChannelRUSH processes these categories of personal information differently because the direct relationship we have with you, our customer, is different than the indirect relationship we have with your end customers.

Data protection and privacy laws in certain jurisdictions, like the European Economic Area (EEA), differentiate between "controllers" and "processors" of personal information.

A controller decides why and how to process personal information.

A processor processes personal information on behalf of a controller based on the controller’s instructions.

When ChannelRUSH processes your Direct Customer Data, the ChannelRUSH entity with whom you are contracting is acting as a controller.

When ChannelRUSH processes Indirect Customer Data, the ChannelRUSH entity with whom you are contracting is acting as a processor.


How We Processes Your Personal Information

We, ChannelRUSH, collect and process your personal information:

  • When you visit one of our public facing websites such as channelrush.com and make a request to receive information about ChannelRUSH products and services;
  • When you contact ChannelRUSH's Sales Team or Customer Support Team; and
  • When you sign up for a ChannelRUSH account and use our products and services

We call this information Direct Customer Data.

Broadly speaking, we use Direct Customer Data to further our legitimate interests to:

  • understand who our customers and potential customers are and their interests in ChannelRUSH's product and services,
  • manage our relationship with you and other customers,
  • carry out core business operations such as product and service fulfillment, accounting, and filing taxes
We do not sell your Direct or Indirect Customer Information, and we do not share your Direct or Indirect Customer Information with third parties for those third parties’ own business interests.


What Customer Account Data We Processes When You Sign Up for and Log Into a ChannelRUSH Account and Why

When you sign up for a ChannelRUSH account, we ask for certain information like your contact details and billing information so we can communicate with you and so you can pay for our products and services. We also collect some information automatically, like your IP address, when you log in to your account or when your software application built on ChannelRUSH makes requests to our APIs. We use this to understand who is using our services and how, and to detect, prevent and investigate fraud, abuse, or security incidents.


Other Direct Customer Data We Collect and Why

We may collect information about you, as our customer, from publicly-available sources so we can understand our customer base better.


How Long We Store Your Personal Information

ChannelRUSH will store your Direct Customer Data as long as needed to provide you with our services and to operate our business. If you ask ChannelRUSH to delete specific personal information from your Direct Customer Data (see 'How To Make Choices About Your Personal Information' below), we will honor this request unless deleting that information prevents us from carrying out necessary business functions, like billing for our services, calculating taxes, or conducting required audits.


How We Processes Your End Customers' Personal Information

Your end customer's personal information typically shows up on ChannelRUSH’s platform contained in lodging reservation information. This personal information was generated at a point of sale by the data controller, and passed to ChannelRUSH for processing as a data processor.

As noted above, data protection (aka privacy) law in certain jurisdictions, like the EEA, differentiate between "controllers" and "processors" of personal information. When ChannelRUSH processes your customer's data, we act as a processor.


How Long We Store Your End Customers' Personal Information

ChannelRUSH will store your Indirect Customer Data as long as needed to provide you with our services and to operate our business. After that we offer data retention controls that you can utilize to determine how long you want access to the personal information, after which time personal information is anonymized or deleted in our system.


How We Secure Personal Information

We take appropriate administrative, physical, and technical measures (collectively "Security Measures") to protect your personal information from loss, misuse, unauthorized access or disclosure, alteration and destruction. We follow generally accepted standards when implementing and maintaining such Security Measures, including, but not limited to, TLS/SSL for data in transit, limiting unnecessary access, using encryption, monitoring for unauthorized access attempts, and mitigating activities by bad actors. These Security Measures are periodically reviewed and, if necessary, updated to ensure they meet current and generally accepted best practices. Furthermore, only authorized personnel have access to personally identifiable information on a need to know basis. We also take measures to ensure service providers that process personal data on our behalf also have appropriate security controls in place.


How to Make Choices About Your Personal Information

You can make various choices about your Direct Customer Data through the account portal, such as accessing it, correcting it, deleting it, or updating your choices about how it is used. Any other requests about your data you cannot make through these self-service tools, you can request by emailingor contacting ChannelRUSH Customer Support.


GDPR, Privacy Shield, and Transfers of Personal Information Out of the EEA and Switzerland

When you use our account portal, or our other products and services, personal information of you and your end users processed by ChannelRUSH may be transferred to the United States, where our primary processing facilities are located, and possibly to other countries where we or our service providers operate. These transfers will often be made in connection with routing your communications in the most efficient way.

ChannelRUSH employs appropriate safeguards for cross-border transfers of personal data, as required by applicable local law, including the EU-U.S. Privacy Shield and Swiss - U.S. Privacy Shield Frameworks.


EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield

ChannelRUSH complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, respectively. ChannelRUSH has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov.


GDPR

GDPR (General Data Protection Regulation) is a new set of rules - effective beginning May 25, 2018 - imposed by the European Union on all organizations worldwide that collect or process data about EU citizens.

If you are a visitor/customer located in the European Economic Area ("EEA"), ChannelRUSH Limited, a UK company, is the data controller of your personal information. ChannelRUSH's Data Protection Officer can be contacted at.


Other Information You May Find Useful

Here's some other information about our privacy practices, such as how we handle certain types of data like children's data, how we handle do-not-track signals, what to expect if we make changes to our notice, and the legal bases for processing personal information.


Contact Us / Disputes

ChannelRUSH tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.

We hope we can resolve any disputes relating to our data protection practices between us. You can raise your thoughts, concerns, or dispute by emailing our Privacy Team ator by writing to us at:

ChannelRUSH
1550 Larimer Street, Suite 290
Denver, CO 80202

For individuals in the EEA, you have additional rights to make a complaint to a competent data protection authority or commence proceedings in a court of competent jurisdiction in accordance with applicable data protection laws.