Privacy Policy

How We Oversee Data

This Privacy Notice describes how Compass Hotel Naples   collects, uses, shares, and retains personal information that you provide to us, or that we collect, when you use the Compass Hotel Naples  website located at https://www.margaritavilleresorts.com/compass-hotel-naples.   Please read the following to learn more about how we collect, store, use and disclose information about you when you interact or use our websites (collectively the “Websites”) or any related events, trade shows, sales or marketing, and/or if you use any of our products, services or applications (collectively the “Services”) in any manner.

What Data Does Compass Hotel Naples Collect?
We collect personal information and non-personal user data from the Service, as further described in this Privacy Notice.  The specific data Compass Hotel Naples  collects, stores and processes depends on which of our products and service you use and how you use them. 
Personal information means information that identifies, describes, or is reasonably capable of being associated with a particular consumer, and includes identifiers such as a name, online identifiers such as device ID, and email address.

Data You Voluntarily Provide through the Service
We use different methods to collect data from and about you including through Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by postal mail, phone, email or otherwise. This includes personal data you provide when you:

• make an order for our products or services.
• create an account on our Site.
• subscribe to our service or publications.
• request marketing sent to you.
• enter a competition, promotion, or survey.
• log in to our guest Wi-Fi provided by the Company; or
• give us feedback or contact us.
• request information about planning an event or party with Compass Hotel Naples we collect your contact information and information about the event, such as the preferred date and time. 
•  are browsing our website, we collect information around your interaction with our websites, applications, or advertisements. 
• stay or visit our property, we may collect information such as your name, phone number, email, and address.

Information Automatically Collected Through the Service
We may automatically collect information about you when you use the Service. For example, we will automatically collect information, which may not be personal information, such as your browser type and version, computer and connection information and standard web log information. If you access the Service through a mobile device, we may also be able to identify the location of your mobile device. You may choose not to share your location details with us by adjusting your mobile device’s location services settings. For instructions on changing the relevant settings, please contact your service provider or device manufacturer.

Information You Post on the Service
If you post information on public areas of the Service, that information will be collected and used by Compass Hotel Naples  other users of the Service, and the public. We strongly recommend that you do not post any information through the Service that allows strangers to identify or locate you or that you otherwise do not want to share with the public.

What Data Do Third Parties Collect through the Service?
Adobe Analytics & Google Analytics
We may use Adobe Analytics and Google Analytics, web analysis services provided by Adobe and Google, in order to better understand your use of our Site and how we can improve it. Both of these services (Adobe Analytics and Google Analytics) collect information such as how often users visit a website, what pages you visit when you do so, and what other websites you used prior to coming to such website. These services collect only the IP address assigned to you on the date you visit a website, rather than your name or other identifying information. We do not combine the information collected through the use of Adobe Analytics or Google Analytics with your personal information. Although Adobe Analytics and Google Analytics plant permanent cookies on your web browser to identify you as a unique user the next time you visit a website, the cookies cannot be used by anyone but Adobe and Google. Adobe and Google’s ability to use and share information collected by Adobe Analytics and Google Analytics about your visits to the Site is restricted by the Adobe Analytics and Google Analytics Terms of Use and the Adobe Privacy Policy and the Google Privacy Policy. Adobe and Google utilize the data collected to track and examine the use of the Site, to prepare reports on its activities and share them with other Adobe and Google services. Google may use the data collected on the Site to contextualize and personalize the ads of its own advertising network. To more fully understand how Google may use the data it collects on the Site, please review “How Google uses information from sites or apps that use our services. 

 Margaritaville uses Adobe Analytics and Google Analytics, web analytics tool provided by Google Inc. (“Google”) and Adobe Inc. ("Adobe"). We use Adobe Analytics on the site and some Google Analytics tools as well. Adobe Analytics and Google Analytics use cookies (text files stored on your computer) to analyze your use of the Site. The information generated by the cookies about your use of the Site is usually transmitted to an Adobe server and/or Google server in the United States and stored there. However, both Adobe and Google use IP anonymization tools on the Site, with which your IP address is shortened by Adobe and Google and anonymously transmitted on a global basis. This means that whether your IP address is collected from the United States, one of the member states of the European Union, the European Economic Area or Switzerland (collectively, the “EEA”), or anywhere else in the world, it will be transmitted using Adobe and Google’s IP anonymization tools and will not disclose any personal data. Adobe and Google use the non-personal data information collected to evaluate your use of the Site on our behalf, to create reports for us about activity on the Site and to provide us with other services related to the Service. The IP address provided by Adobe Analytics and Google Analytics as part of the Adobe Analytics and Google Analytics services will not be merged with other Adobe or Google data. 

Information Collected by Third Parties through Third Party Links and Content
The Service includes links to other websites and other content from third party businesses. These third party businesses may collect information about you. Margaritaville Beach Resort Ft Myers Beach does not have access to or control over these third parties or the cookies, web beacons or other technology that these third parties may use. We are not responsible for the privacy practices of these third parties or the content on any third party website. You are encouraged to review the privacy policies of the different websites you visit and of the advertisers whose ads you may choose to click while on our Service (also please see our Cookie Policy for additional information about Online Advertising).

Cookie Policy

A cookie is a small piece of data (text file) that a website – when visited by a user – asks your browser to store on your device to remember information about you, such as your language preference or login information. Those cookies are set by us and called first party cookies. We also use third party cookies – which are cookies from a domain different than the domain of the website you are visiting – for our advertising and marketing efforts.

• More specifically, we use cookies and other tracking technologies for the following purposes:
• Assisting you in navigation.
• Assisting in login and your ability to provide feedback.
• Analyzing your use of our products, services, or applications.
• Assisting with our promotional and marketing efforts. 

Below is a detailed list of the cookies we use on our website. Our website is scanned with our cookie scanning tool regularly to maintain a list as accurate as possible. We classify cookies in the following categories:

• Strictly Necessary Cookies
• Statistics Cookies

Strictly Necessary Cookies

These cookies are necessary for the website to function and cannot be turned off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms.

You can set your browser to block or alert you about these cookies, but some parts of the site will not work. These cookies do not store any personally identifiable information.

• www.margaritaville.com/margaritaville-beach-resort-fort-myers-beach
• BubbleUp, LLC - www.bubbleup.net
• Cendyn - www.cendyn.com
• Margaritaville Brand - www.margaritaville.com
• My Emma - myemma.com
• NET CONVERSION - https://netconversion.com/

Statistics Cookies

These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us know which pages are the most and least popular and see how visitors move around the site. They may be set by us or by third party providers whose services we have added to our pages. Those companies may use cookies to build a profile of your interests and show you relevant adverts on other sites. They do not store personal information directly but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

• Adform - site.adform.com
• AudioEye, Inc - https://www.audioeye.com/
• AvantLink - www.avantlink.com
• Double Smart Digital - https://doublesmart.digital/
• Facebook API - www.facebook.com
• Flip.To - www.flip.to
• Google Analytics - google.com
• Linkedin - www.linkedin.com
• The Hotels Network - www.thehotelsnetwork.com
• TripAdvisor - www.tripadvisor.com
• Yelp, Inc. - www.yelp.com

NAME	WEBSITE	WHY	REQUIRED	EMAIL
Margaritaville Brand	www.margaritaville.com	Email marketing	Yes	info@margaritaville.com
BubbleUp, LLC	www.bubbleup.net	Website hosting and management company providing essential components for functionality of this website	Yes	mydata@bubbleup.net
Cendyn	www.cendyn.com	For email delivery relating to the resort and loyalty program	Yes	info@cendyn.com
Verb Interactive	https://www.verbinteractive.com/	designing, deploying, analyzing, and reporting on digital marketing campaigns	Yes	sales@verbinteractive.com

How Do We Use Your Information?
Subject to applicable laws, we may use, collect, and disclose your information for the following purposes:
- Websites: We will use the information we collect via our websites:

• To administer our website and for internal operations, including troubleshooting, data analysis, testing, statistical and survey purposes.
• To improve our website to ensure that content is presented in the most effective manner for you and for your computer;
• To analyze customers’ use of the Websites for trend monitoring, marketing, and advertising purposes.
• For purposes made clear to you at the time you submit your information – for example, to provide you with information you have requested about our Services.
• As part of our efforts to keep our website safe and secure.

-Services: We may use the information we collect from our customers and their users in connection with the Services we provide for a range of reasons, including to:

• Set up a user/membership account.
• Provide, operate, and maintain the services.
• Process and complete transactions, and send related information, including transaction confirmations and invoices.
• Manage use of the Services, respond to inquiries and comments, and provide customer service and support.
• Send customers technical alerts, updates, security notifications, and administrative communications.
• Investigate and prevent fraudulent activities, unauthorized access to the Services, and other illegal activities; and

1. Fulfilling Requests
If you provide your information to us for a particular purpose, we will use the information you provide for the applicable purpose. Below is a list of examples where we may use your information to fulfill requests:

•  Provide you with customer support at Compass Hotel Naples  
• Provide you with a more personalized level of service at Compass Hotel Naples  and through our digital channels, including websites and applications.
• Fulfill contractual obligations to you or anyone you involve as part of making your travel and reservation arrangements, such as an agency or travel agent.
• Verify your identity for requests made with regards to your personal information. 

2. Operating the Service
We use the information we gather through the Service to help us better understand how the Service and our products and services are being used. By identifying patterns and trends in usage, we are able to better design the Service to improve your experience. We use your information for this purpose in the following ways:                    

• Conduct customer satisfaction and quality assurance surveys.
• Provide for the safety and security of the team members and staff, guests, or other visitors at Compass Hotel Naples .
• Prevent, identify, and investigate potential or actual illegal activity such as cyber incidents and types of fraud.
• Communicate with you updates to any terms, conditions, policies or other information about our relationship.
• Evaluate new products or services.

3. Direct Marketing Communications
If you sign up for our mailing list, sign up for our newsletter, or purchase goods or services, we will use the personal information and other information you provide to send you marketing communications. If you no longer wish to receive these marketing materials, please follow the instructions contained in our marketing materials that allow users to unsubscribe from receiving these types of communications from us. If you unsubscribe from our direct marketing communications, we will remove your email information from our marketing list.

How Do We Share Your Information?
We share your personal information and other information with third parties in some circumstances as follows:

1. Response to Subpoenas or Court Orders or to Protect Rights and to Comply with Our Policies 
To the extent permitted by law, we will disclose your information to government authorities or third parties if:  (a) required to do so by law, or in response to a subpoena or court order; (b) we believe in our sole discretion that disclosure is reasonably necessary to protect against fraud, to protect the property or other rights of us or other users, third parties or the public at large; (c) we believe that you have abused the Service by using it to attack other systems or to gain unauthorized access to any other system, to engage in spamming or otherwise to violate applicable laws; (d) in response to a request from law enforcement authorities or other government officials, including to meet national security requirements; or (e) when we believe disclosure is reasonably necessary or appropriate to prevent physical harm or financial loss in connection with an investigation of suspected or illegal activity.

2. Business Transfers: Bankruptcy 
In the event of a merger, acquisition, bankruptcy or other sale of all or a portion of our assets, any user information owned or controlled by us may be one of the assets transferred to third parties. We reserve the right, as part of this type of transaction, to transfer or assign your information and other information we have collected to third parties.

3. Aggregate & Deidentified Information 
We may share aggregate information relating to users of the Service with affiliated or unaffiliated third parties. We also may use and share some information that has been deidentified in accordance with applicable legal standards.

4. Marketing Partners
As permitted by applicable law or based on your consent, we may share your personal information with our business partners for marketing purposes such as reservation management, customer relations management (e.g., customizing your preferences when you stay at our resort), or administering a customer loyalty program. If you would like us to stop providing your personal information as described above, you may opt-out by emailing us at admin@tpimn.com. 

5. To Protect You, Us, or Others 
We may share your personal information if we believe, in good faith, that such disclosure would protect your interests or rights, safety, or the interests or rights of others, including Compass Hotel Naples  and its personnel.

Where is the Data Processed & Stored?
Personal information processed by Compass Hotel Naples  is processed and stored by Compass Hotel Naples , and at times through the use of third-party service providers, in the United States. Compass Hotel Naples  implements and maintains reasonable security procedures and practices such as physical, technical and administrative measures to safeguard all personal information that Compass Hotel Naples  processes. Please be aware that no data transmission over the Internet can be guaranteed to be 100% secure. As a result, we cannot guarantee or warrant the security of any personal information that we process.

Responding to Concerns 
We take your privacy concerns seriously. If you believe that Compass Hotel Naples  has not adhered to this Privacy Notice, please contact us by sending an email to: admin@tpimn.com with the subject line:  “Privacy Concern”. In your email, please describe the ways in which you believe that this Privacy Notice has not been complied with or does not comply with applicable law.

Children
Our Services are not directed to children under the age of 13. We adhere to the Children’s Online Privacy Protection Act (“COPPA”) and will not knowingly collect personal information from any child under the age of 13, unless a parent or guardian consents to our collection and use of this information. If a parent or guardian becomes aware that his or her child has provided us with personal information without his or her consent, he or she should contact us at admin@tpimn.com.  If we become aware that a child under 13 has provided us with personal information, we will take steps to delete the information from our files.

Data Subject Rights – California Residents 
This portion of our Privacy Notice advises California residents of the applicable rights as provided in the California Consumer Privacy Act (“CCPA”) and how to exercise these rights by communicating with us. We provide you with the rights described below when you use our Services. Please note that we will seek to verify your identity when we receive an individual rights request from you in order to ensure the security of your personal information.
For purposes of this section, “Personal Information” is defined as information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
If a California resident wishes to make any of the requests described below, such as access and deletion, he or she may contact us as provided in Section 13 (How to Contact Us) below.

Right to Deletion of Personal Information 
California residents have the right to request the deletion of Personal Information as prescribed in Section 1798.105(a) of the CCPA. Compass Hotel Naples  may not delete some or all Personal Information if such Personal Information is necessary for us, or our service providers or affiliates, to: Complete the transaction for which the Personal Information was collected, provide a good or service requested by the consumer, or reasonably anticipated within the context of Margaritaville’s Beach Resort Fort Myers Beach ongoing business relationship with the consumer, or otherwise perform a contract between Compass Hotel Naples  and the consumer,

• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity,
• Debug to identify and repair errors that impair existing intended functionality,
• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law, 
• Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code,
• Enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with Compass Hotel Naples
• Comply with a legal obligation, or
• Otherwise use the consumer’s Personal Information, internally, in a lawful manner that is compatible with the context in which the consumer provided the Personal Information.

Right of Access: Right to Request Disclosure of Data Collection and Sharing Practices 
You may request to receive details about how we collect, use, and share your Personal Information.  Specifically, you may request to receive the specific pieces of information that we have collected about you by contacting us as provided in Section 13 (How to Contact Us) below. 
You may also request to receive:

• the categories of Personal Information that we have collected about you, 
• the categories of Personal Information that we have disclosed for a business purpose, 
• the categories of sources from which we collected the Personal Information,
• our purposes for collecting that Personal Information, and
• the categories of parties with whom we share your Personal Information.

Right to not be Discriminated Against for Exercising your Rights 
We do not discriminate against you for exercising any of your CCPA rights, such as your access and deletion rights described above. However, we may offer you rewards (such as through our loyalty program) or benefits (such as customizing your experience at a resort) which we need your data to provide, but we will only provide those rewards or benefits if their value to you is reasonably related to the value provided to Compass Hotel Naples by your Personal Information. 

Categories of Personal Information Collected about California Consumers and the Purposes of Such Collection 
We collect identifiers that you may choose to provide to us, such as your name, email address, mailing address, phone number, birthday, and age. We use this information to communicate with you, market goods and services, and to provide you with goods and services. We collect and use identifiers (such as a username) you may choose to provide to us, and the content of your communications when you post information on our online message boards or online public forums. We use this information to run our online message boards or online public forums.

Categories of Personal Information Sold about California Consumers 
Compass Hotel Naples does not sell consumers’ Personal Information.

Categories of Personal Information Disclosed for a Business Purpose 
Compass Hotel Naples discloses identifiers (e.g., name or email address), internet activity, consumer history, and consumers’ preferences to provide marketing and analytics services to its business partners. 
Compass Hotel Naples discloses identifiers, consumer history, and consumers’ preferences to our franchisees and licensees to offer our Services. 
Compass Hotel Naples may share your personal information with third-party service providers that perform a variety of services on our behalf, such as the development and analysis of our social media pages, operating and maintaining our websites, offering or managing promotions, and market research purposes. 
Compass Hotel Naples may share your personal information with other entities for purposes of a sale, merger, or other related corporate event. An entity that buys us or a part of our business may continue to use your personal information in accordance with this Privacy Notice.
 

Removing Content on Public Forums 
If you are a California resident between the age of 13 and 18 and are a registered user on the Service and participate in the online public forums offered through the Service, you may request that we remove content or information about you that you posted by (a) submitting a request in writing to admin@tpimn.com with the subject:  “Deletion Request”, and (b) clearly identifying the content or information you wish to have removed and providing sufficient information to allow us to locate the content or information to be removed. However, please note that we are not required to erase or otherwise eliminate content or information if (i) other state or federal laws require us or a third party to maintain the content or information; (ii) the content or information was posted, stored, or republished by another user; (iii) the content or information is anonymized so that you cannot be individually identified; (iv) you do not follow the instructions posted in this Privacy Notice on how to request removal of your content or information; or (v) you have received compensation or other consideration for providing the content. Further, nothing in this provision shall be construed to limit the authority of a law enforcement agency to obtain the applicable content or information.

Responding to Do not Track Requests 
We are required to indicate whether we honor “Do Not Track” settings in your browser concerning targeted advertising. “Do Not Track” is a standard that is currently under development. As it is not yet finalized, we adhere to the standards set out in this Privacy Notice and do not monitor or follow any Do Not Track browser requests.

Data Retention
We will retain your personal information only for as long as reasonably necessary for the purposes described in this Privacy Notice. Please be aware that we may also be required to retain your personal information for legal and accounting reasons.

Changes to this Privacy Notice 
We reserve the right, in our discretion, to amend this Privacy Notice at any time without notice and, unless otherwise indicated, such changes will become effective immediately upon posting; therefore, please check this Privacy Notice periodically for changes. We will display the effective date of this Privacy Notice at the top of this page. If you do not agree with the changes and if you are a registered user, you may cancel your account with us by contacting us at admin@tpimn.com.  The version of this Privacy Notice posted here on each respective date you visit the System shall be the Privacy Notice applicable to your access and use of the System on that date. Our electronically or otherwise properly stored copy of this Privacy Notice shall be deemed to be the true, complete, valid, authentic, and enforceable copy of the version of this Privacy Notice which was in force on each respective date you visited the System.  This Privacy Notice is not a contract and does not create any legal rights or obligations.

13. How to Contact Us 
If you have any questions or concerns about this Privacy Notice or would like to make a request for access or deletion, please contact us by sending an email to admin@tpimn.com.