Privacy Policy

Our Privacy Policy

Privacy Policy

We are VOMOS, Inc. (“VOMOS”, “we”, “us” and “our”). VOMOS is a near demand marketplace service that connects people (“Customers”) seeking to rent vacation homes and villas, private jets, yacht charters, exotic cars and limousines with the verified owners of these assets (“Vendors”). Together, the Customers and Vendors are referred to as “users” of the Service. This Privacy Statement discusses our privacy practices.

We provide the service of matching Customers and Vendors (the “Services”) through our website at VOMOS.com (the “Site”), mobile applications (the “Software”), electronic mail, texts, and other forms of electronic communications.

Each person or entity who uses our Services is referred to as a “user” or “you” or “your”. If you subscribe to any of our Services, we will refer to you as a “registered user”. If you don’t register with us, we will refer to you as an “unregistered user”.

This document is our statement of our privacy practices (“Privacy Statement”). Among other things, it explains how we and some of the companies we work with collect, use, share and protect the information you provide to us (“your Content” or “User Content”). The User Content may include any personally-identifiable information, including without limitation name, address, telephone numbers, electronic mail and postal addresses, personal health information, personal financial information, and other sensitive information that identifies or is uniquely associated with an individual (collectively, “Personal Data”). This Privacy Statement also discusses your choices about the collection, storage and use of your Personal Data.

Any Content that is not Personal Data is referred to as “Non-Personal Data.” Non-Personal Data includes information about how users use the Services, what Services users select, how users respond to service offerings, how users share information with others, what users say they like and dislike, all of which we aggregate into larger data sets that do not identify individuals (“Behavioral Data”).

Among other Services, in addition to connecting Customers and Vendors, VOMOS connects users with other companies (collectively, “Partners”). This Privacy Statement does not apply to any Partners or to any other websites, mobile applications, individuals, businesses or organizations. This Privacy Statement does not apply to any Personal Data or other Content collected via any means other than the Services. For clarity, this Privacy Statement does not apply to any privacy practices of the users, such as Personal Data collected by Customers and Vendors when connected by VOMOS.

1. Information We Collect

As noted above, we collect Content from you while providing the Services. Some of the Content is Personal Data that we use to contact you and our Partners, and which is necessary to provide the Services. Other Content we collect from you includes Behavioral Data and other Non- Personal Data that we aggregate, share, and use to improve our Services, the services of our Partners, and others in the industry.

We collect many different types of information from you, both directly and indirectly.

Information you provide us directly

  • Registration information. When you create or modify an account, or subscribe to our Services, you provide Personal Data to us, such as your user name, age or age-range (to confirm the user as an adult), password, telephone number (for SMS/texts and phone calls), postal address and email address.

  • Payment information. We use a third-party payment processor (“Processor”) to process your payments, so we do not store your credit card numbers or other payment information. Please note that our Processor does store and process your credit card numbers and other payment information in accordance with the Processor’s privacy policies and privacy statement, and subject to applicable law.

  • Profile information. You may provide us with additional profile information that you choose to make public or share with other users. You may also provide information to customize your account, such as a telephone number for the delivery of short message system (“SMS”) or text messages. Each individual user may connect with other users and third parties to share their puzzles and other Personal Data and Content. Similarly, Partners and other third parties may provide their Personal Data and Content to the Services to attract and communicate with users, share puzzles and other Content. We may use your contact information and other Personal Data to send you information about our Services, or to market to you. You may use your account settings to customize notifications from us. If you email us, we may keep your message, email address and contact information to respond to your request.

  • Location Information. We may ask for your postal address or your geographic location information, especially if you place an order for Services with us. When you post User Content to our website or to social media, you may provide your location information, including global positioning system (“GPS”) data or other location information embedded in or accompanying the User Content (e.g., in tags or captions) or embedded in the User Content.

  • Communications between you and VOMOS. We may send you emails, SMS or text messages, and other electronic communications for sales and delivery, account verification, notices of changes/updates to features of the Services, technical and security notices, and for other purposes. We may collect and store these communications.

Information we gather from your use of our Services

  • Emails. We collect and may save private emails sent to us by users, and we may share your emails with any third parties or other users. Any public posts on Services may be viewed by any user and is public to anyone who visits the Services. You may elect to disclose certain Personal Data and Non-Personal Data. The information you submit to any public forums is not confidential or private, and VOMOS does not protect it. All information you choose to provide publicly, including information that identifies you or others, can be read, collected, or used by other users and by other third parties, and could be used to send you unsolicited messages and for other purposes.

  • Social Media. In addition to media that we control, you may post comments, photographs, drawings and other User Content on third-party social media, such as Facebook, SnapChat, Instagram and Twitter, each of which enforces its own terms of use and privacy policy for its service. As noted in the Terms and our other online documents, we may use and copy the User Content you post. More to the point, your User Content may contain Personal Data about you and other people in the form of names, email addresses, personal health information, and location information. You should also be aware that a photograph, drawing or other image of a person may be Personal Data to the extent the person may be recognized in and identified by the photograph or drawing, and medical or other healthcare information may be gleaned from any medical conditions, disorders or diseases are discussed or portrayed in the User Content. We may collect and use User Content and the Personal Data contained in the User Content to market our Services.

  • Analytics. We use third-party analytics tools (currently, Google Analytics) to help us measure traffic and usage trends and other Non-Personal Data for the Services. These tools collect information sent by your device or our Services, including the web pages you visit, add-ons, and other information that assists us in improving our Services. We collect and combine this analytics information with analytics information from other users so that it cannot be used to identify any particular individual user.

  • Metadata. Metadata is usually technical data that is associated with other data, including User Content. For example, metadata can describe how, when and by whom an item of User Content was collected and how that User Content is formatted. VOMOS may collect and store metadata, including about each user’s public posts on the Services.

  • Links. VOMOS may keep track of how you interact with links across our Services, including our email notifications and third-party Services by redirecting clicks or through other means. We do this to help improve our Services, to provide more relevant local data, and to be able to share aggregate click statistics such as how many times a particular link was clicked on.

  • Device Identifiers. We may access, collect, monitor, store on your device, or remotely store one or more “device identifiers.” Device identifiers are small data files or similar data structures stored on or associated with your computer, phone or other device, which uniquely identifies your device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to the device by VOMOS. A device identifier may deliver information to us or to a third-party partner about how you browse and use the Services and may help us or others provide reports or personalized Content and ads. Some features of the Services may not function properly if use or availability of device identifiers is impaired or disabled.

  • Log Data. Our servers automatically record information (“log data”) created by your use of the Services. Log Data may include information such as your Internet Protocol (“IP”) address, browser type, operating system, the referring web page, pages visited, location, your mobile carrier, device and application IDs, search terms, and cookie information. We receive log data when you interact with our Services, for example, when you visit our website, sign into our Services or interact with our email notifications. VOMOS uses log data to review how we provide our Services and to measure, customize, and improve the Services.

2. How We Store Your Information

  • We currently provide the Services from within the United States, and we store all User Content, including Personal Data, that we currently collect and retain on servers located inside the United States.

  • In the future, we may store Personal Data and other User Content on servers located outside the United States.

  • Certain types of User Content you submit to us might reveal your gender, ethnic origin, nationality, age, religion, sexual orientation, or other Personal Data or sensitive information about you or others.

  • By using our Services, or by submitting your Personal Data to us, you consent to the collection, storage, processing and onward transfer of your Personal Data as stated in the current version of this Privacy Statement and the current version of our other online documents, including the Terms of Service.

3. How We Use Your Information

We share and use your Personal Data as follows:

  • Lawful Basis. The lawful basis for our processing some of your Personal Data (e.g., Personal Data relating to your credit and your method of payment) is that it is necessary to provide the Services. We cannot connect Customers and Vendors for the use of Assets otherwise. For other Personal Data that is not needed by us to provide the Services (“non-essential Personal Data”), by submitting non-essential Personal Data to us you consent to the collection, storage, processing, use, sharing, and onward transfer of your non-essential Personal Data.

  • Opt-in with Your Consent. We may ask for your permission to share your Personal Data with other people and organizations outside of VOMOS, including to help conduct studies or provide you with other Services. As with any opt-in procedure, you are under no duty to agree to a request that you opt-in.

  • Partners and Affiliates of VOMOS. We may share your Personal Data with Partners and with our VOMOS affiliates (meaning entities controlled by, controlling or under common control with VOMOS) as necessary to provide the Services.

  • Cookies. Cookies are unique identifiers that we transfer to your device to enable our systems to recognize your device and to provide features and remember your personalization choices. We use cookies to make it easier to access and use our Services. The help feature on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Additionally, you can disable or delete similar data used by browser add-ons, such as Flash cookies, by changing the add-on’s settings or visiting the website of its manufacturer. Because cookies allow you to take advantage of some of the Services’ essential features, we recommend that you leave them turned on. Cookies are also used to display particular Content and to set session identifiers for visitors who voluntarily join user areas.

  • Opt-out Email or Postal Address. If you supply us with your postal or email address you may receive periodic mailings from us with information on new Services or upcoming events. If you do not want to receive mailings from us, please let us know by sending an email to us at the “opt-out” address, below. We will remove your name from the list we use internally. Opting-out of these emails does not mean we remove your email from our system entirely, because we still retain your email addresses for other purposes stated in this Privacy Statement.

  • Service Providers. We employ third-party companies and individuals to facilitate our Services (e.g., payment processing, maintenance, analysis, audit, marketing and development). These third parties may have limited access to your Personal Data only to perform these tasks on our behalf and are obligated to VOMOS not to disclose or use your Personal Data for other purposes.

  • Required by Law. We may access, preserve and share your Personal Data in response to a legal request (such as a search warrant, court order or subpoena) or requirement (such as passenger name records for flights as required by applicable regulations). We may also access, preserve and share Personal Data when we have a good faith belief it is necessary to: detect, prevent and address fraud and other illegal activity; to protect ourselves, you and others, including as part of investigations; and to prevent death or imminent bodily harm. Information we receive about you may be accessed, processed and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm.

  • National Security and Intelligence Activities. We may release your Personal Data to authorized federal officials for intelligence, counterintelligence and other national security activities when required by law. For example, under current law in the United States, certain federal officials may require that we provide Personal Data and other Content in response to a national security letter, subpoena, demand, or court order. In some cases, we would be required not to tell you that we complied with that letter, subpoena, demand, or court order. Where permitted by applicable law, we reserve the right to comply with, or to fight or quash, any such letter, subpoena, demand, or court order.

  • Change of Control. If we sell or otherwise transfer part or the whole of VOMOS or our assets to another organization (e.g., a merger, acquisition, or reorganization), your Personal Data such as user name and email address, User Content and any other information collected through the Services may be among the items sold or transferred. You will continue to own your User Content, but the license you grant to us in the Terms may be transferred to others.

  • Non-Personal Data. We may share Non-Personal Data publicly and with publishers, researchers or connected sites. For example, we may share aggregated Non-Personal Data publicly to show trends about the general use of our Services. Non-Personal Data includes aggregated or collective information about multiple users that does not reflect or reference an individually-identifiable user.

  • Other. In addition to some of the specific uses of information we describe in this Privacy Statement above, we may use Personal Data that we receive to:

    • help you efficiently access your information after you sign in.
    • remember information so you will not have to re-enter it during your visit or the next time you visit the Services.
    • provide personalized Content and information to you and others, which, in the future, could include online advertising or other forms of marketing.
    • provide, improve, test, and monitor the effectiveness of our Services.
    • develop and test new products and features.
    • monitor metrics such as total number of visitors, traffic, and demographic patterns.
    • diagnose or fix technology problems.

4. Your Right to Review, Request Changes, and Disclose Personal Data

Subject to applicable laws and regulations, each user may inspect and receive a copy of his or her Personal Data is stored in the Services. In rare circumstances, we may deny a request, and we may provide you with an explanation (unless prohibited by applicable law). If we deny your request, you may request a review by another professional, who will be chosen by VOMOS, and we will comply with the outcome of the review.

Subject to applicable laws and regulations, the Personal Data you provide to us remains completely under your control. If you believe the Personal Data we have is incorrect or incomplete, or if you would like us to delete your Personal Data, you may in writing request an amendment to your Personal Data or the deletion of your Personal Data. We will approve or deny each request, and notify you of our decision. If approved, we will amend or delete the Personal Data we have in our records as requested by you. We will also make a reasonable effort to notify people to whom the Personal Data was released. In the case of a denial, we will provide the reason for the denial.

Please understand that any information or User Content that you voluntarily disclose for use of the Services, such as your user name, your Personal Data or your User Content, may become available to the public if you release it to other users or to the general public. Once you have shared your Personal Data or your User Content with other people, or otherwise made it public, that Personal Data and your User Content may be re-shared by others.

5. Children and Young Adults

Our Services are not directed to persons under age 21. Some of our Assets and related Services may be available to only older adults (e.g., minimum age 25 or 30), as set by the Vendors.

If you are the parent or guardian of a person under 21, and you become aware that your young person has provided us with Personal Data or User Content without your express consent, please contact us at contact@vomos.com and we will remove the information or User Content, and we will terminate the young person’s account. You may then establish an account that you manage for your child or guardian.

6. Changes to this Privacy Statement

We may modify our Privacy Statement from time to time on prior written notice sent to the email address we have for you. For any user who has not provided us with an email address, the revised Privacy Statement will become effective when posted on the Services. If you choose not to be subject to a revised version of this Privacy Statement, then you may terminate your account with us.

7. Different Locations, Different Laws

The laws and regulations that address privacy rights and responsibilities (collectively, “Laws”) are different from one to another. Indeed, some of the Laws do or do not apply depending on different factors, including:

  • Location or residence of the user.
  • Location or residence of the individual that is the subject of the Personal Data (“Data Subject”).
  • Location or residence of the person or organization that employs or contracts with the Data Subject.
  • Location of each server or other machine where the Personal Data is received, stored, processed or forwarded to.
  • Location of the relevant office of VOMOS.

Several of the Laws that concern unregistered users, registered users, and VOMOS are discussed in this Section, but these are not all of the Laws that may apply. In addition, if there is any conflict or ambiguity between the statements made in this Privacy Statement and an applicable Law, then the Law will control.

7.1 United States Federal Laws

Several of the federal Laws in the United States may apply to the Personal Data collected by us.

Currently, all Personal Data of users resident in the United States is stored on servers and other machines physically located within the United States.

7.1.1 Health Insurance Portability and Accountability Act (“HIPAA”)

Currently, HIPAA does not apply to the Services as we are neither a covered entity nor a business associate (as those terms are used in HIPAA).

7.1.2 Children’s Online Privacy Protection Act (“COPPA”)

Currently, COPPA does not apply to the Services. Each registered user and other user must be 21 years of age or older. As noted in this Privacy Statement, if we learn of any registered user is under the age of 21, or if any parent or guardian of a user under the age of 21 contacts us, we will close that user’s account and remove all information provided by the individual from our Services.

7.2 State Laws in the United States

Individual states in the United States have passed and enforced information privacy and security laws.

7.2.1 Your California Privacy Rights

If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your Personal Data by us to third parties for the third parties’ direct marketing purposes. To make such a request, please send an email to contact@vomos.com, or send us postal mail at:

Attn: Privacy, VOMOS, Inc., 1 Winding Drive, Suite 206, Philadelphia, PA 19131, USA.

Pursuant to California Civil Code Section 1798.83(c)(2), we do not currently share users’ Personal Data with affiliate companies or others outside VOMOS for those parties’ direct marketing use, unless a user elects that we do so.

If you are a California resident under the age of 18, and a subscriber of any site where this Privacy Statement is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to contact@vomos.com. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal, even if requested.

By submitting any Personal Data or other User Content to us, or placing any order with us, you consent to the storage, processing, use and onward transfer of your Personal Data and User Content to us in the United States.

8. Use of Email Addresses and Other Contact Information

We collect the email addresses of those who voluntarily provide them to us, including unregistered users and registered users. You may receive subscription, editorial and other messages from the Services or from us. If you do not want to receive email from us in the future, please let us know at contact@vomos.com.

9. Contact Us

If you have questions or concerns about this Privacy Statement, please contact us online at contact@vomos.com, or by postal mail addressed to:

Attn: Privacy, VOMOS, Inc., 1 Winding Drive, Suite 206, Philadelphia, PA 19131, USA.

10. Revision Date and History

These Terms were last revised: September 12, 2020.

Prior versions of this Privacy Statement are listed below:

  • August 1, 2018

Privacy Policy Mobile

1. Scope.

This Privacy Policy describes how we handle your personal information on the Vomos.com website (the “Vomos App”), the Vomos mobile and on other related sites, tools, applications, or services. By accepting the Privacy Policy and the Terms of Use when you submit a property contact form on Vomos.com, you expressly consent to our collection, storage, use and disclosure of your personal information as described in this Privacy Policy, including its transfer to and storage on our servers in the United States or elsewhere in the world where Vomos has facilities.

2. Collection.

When you submit a property contact form on the Website we will collect your name and email address. In addition, we may obtain additional information from you if you register an account on Vomos.com. While you can use many functions of Vomos.com without being a registered user, certain activities may require registration. Once you give us your email address or any other personal information, you are not anonymous to us. In most cases, the information we hold about you is collected through Vomos.com, but we may also collect information from private-label, co-branded and affiliate websites and/or from third parties with whom we have entered into an arrangement for such collection, or from their respective tools, applications or services (“Other Sites”). Accordingly, our privacy policy may apply to you even if you are not a registered user of our Website. Depending on the services used, we may collect and store the following personal information:

  • personal and contact information such as name, email address, postal address, telephone number and social security number;
  • self-reported income and/or credit score information;
  • financial information such as credit card or bank account numbers;
  • additional information we may ask you to send or questions we may ask you to answer to verify your identity (such as your driver’s license, credit card statement, and/or a recent utility bill or other information confirming your address);
  • information contained in “eMail Notes and Photos” submissions;
  • lease terms, lease parties and other transactional information;
  • information automatically collected by cookies and web beacons on your computer (for more information about this, please see Cookies, Web Beacons and Your Privacy); and
  • information based on your interactions with Vomos.com or the Other Sites and their advertising, such as search information, computer sign-on data, statistics on page views, traffic to, from and within Vomos.com or Other Sites, ad data, IP address and standard web log information.

We may also collect information about your computer or other access device to mitigate risk and for fraud prevention purposes.

3. Use.

Our primary purpose in collecting personal information is to provide you with a safe, smooth, efficient, and customized experience. We may use your personal information to:

    • provide the services and customer support you request, including confirming emails related to the Vomos.com services, reminders and transactions.
    • contact and communicate with Lessors.
    • resolve disputes, collect fees and troubleshoot problems.
    • customize your experience and otherwise measure and improve Vomos.com’s services.
    • send you relevant residential real estate related listings via email, phone, text messaging or push notification on your phone (provided you have not opted out of such communications).
    • deliver targeted marketing, service updates, and promotional offers based on your communication preferences. (If we use your personal information to market to you, you will be able to opt-out of such uses; see below under Section 5. Communications and Communications Tools; Email Preferences and Section 6. Cookies.)
    • make payments to third parties through the Website or the App, should you choose to do so.
    • request your review of a property.
    • compare information for accuracy and verify it with third parties.
    • measure consumer interest in our products and services.
    • summarize your information (including personal information) that you provided to us or our affiliates.
    • help promote a safe service and detect and prevent error, fraud and other potentially prohibited or illegal activity.
    • enforce our agreements, terms, conditions, and policies, and send you notices and alerts.
    • provide services as otherwise described to you at the time of collection.
    • prepare aggregated data, including for general marketing and analytical purposes.

4. Disclosure.

We reserve the right to use and disclose in any manner, any non-personal, nonidentifiable information including in the form of aggregated data that we collect by use of cookies and traffic data, or that you share with us. However, we will not sell or rent your personal information to any third parties. We may share some or all of your personal information with:

    • Law enforcement offices, third-party rights owners or others in the good faith belief that such disclosure is reasonably necessary to enforce our Terms of Use or Privacy Policy; respond to claims that an advertisement, posting or other content violates the rights of a third party; or protect the rights, property or personal safety
    • f our users or the general public.
    • Other third parties whose services you agree to use (e.g., online rent payment services), with regard to whom you have expressed interest or initiated communication through Property Contact Forms (See Section 5 Communications and Communications Tools), and with whom you have authorized us to share your personal information. (The information we disclose in this way will be subject to those third parties’ privacy policies.)
    • Service providers under contract who help with our business operations (such as fraud investigations, bill collection, invoicing, telecommunication and call monitoring services, rewards programs, co-branded credit cards, etc.).
    • Another business entity should we plan to merge with, or sell substantially all our assets to that business entity. (Should such a combination occur, we will require that the new combined entity follow this privacy policy with respect to your personal information. If your personal information will be used contrary to this policy, you will receive prior notice.)

If you become a registered user, you can opt out of sharing your personal information by sending an email to support@vomos.com.

We reserve the right to use in any manner and disclose any non-personal information that we collect including cookie and traffic data. Logs, recordings, and other information related to communication between you and third parties in connection with the services and/or other uses and purposes mentioned herein may be stored, maintained and/or divulged to those third parties by us on an individual basis or in the aggregate. Without limiting the above, in an effort to respect your privacy, we will not otherwise disclose your personal information to law enforcement, other government officials, or other third parties without a subpoena, court order or substantially similar legal procedure, except when we believe in good faith that the disclosure of information is necessary to prevent imminent physical harm or financial loss or to report suspected illegal activity.

5. Cookies.

We or our service providers may place cookies or web beacons on your computer when you visit portions of Vomos.com. We use permanent cookies to provide personalized features, such as automatically logging you into your personalized home page and to deliver customized services, content, and advertising. We use session cookies, which are deleted when you log out of Vomos.com or browse to a different website, to monitor and improve the functionality and usability of the Website. You can block our cookies by changing the settings on your browser (contact your ISP for help), but doing so may prevent us from delivering certain services to you.

6. Third Parties.

Except as otherwise expressly included herein, this Privacy Policy addresses only the use and disclosure of information we collect from you. If you disclose your information to others, whether they are Renters and Lessors or other websites throughout the Internet, different rules may apply to their use or disclosure of the information you disclose to them. Vomos.com does not control the privacy policies of third parties. We encourage you to ask questions before you disclose your personal information to others.

7. Account Protection.

Your password is the key to your account. Use unique numbers, letters and special characters, and do not disclose your Vomos.com password to anyone. If you do share your password or your personal information with others, remember that you are responsible for all actions taken in the name of your account. If you lose control of your password, you may lose substantial control over your personal information and may be subject to legally binding actions taken on your behalf. Therefore, if your password has been compromised for any reason, you should immediately notify Vomos.com and change your password.

8. Security.

Your information (other than credit card information) is stored on our servers located in the United States. We treat data as an asset that must be protected and use many tools (encryption, passwords, physical security, etc.) to protect your personal information against unauthorized access and disclosure. However, third parties may unlawfully intercept or access transmissions or private communications, and other users may abuse or misuse your personal information that they collect from Vomos.com. Therefore, although we work very hard to protect your privacy, we do not promise, and you should not expect, that your personal information or private communications will always remain private.

9. Minors.

The Website and the App are intended solely for use by persons 13 years of age or older. If you are under the age of 13, you may not use the Website, App or other services, or contribute any information to us.

10.General.

We may amend this Privacy Policy at any time by posting the amended terms on Vomos.com. We’ll provide you with notice of the changes on the Website. Amended terms take effect upon acceptance for new users and 10 days after they are posted on Vomos.com for all other users.

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