Revised January 1, 2020
The CPM Solution is committed to providing you with the best products and services possible. Transparency over how we collect, safeguard and use your information is of paramount importance to us. CPM has developed this PCP to give you a clear understanding of our privacy practices, including how we process (e.g., collect, use and store) your personal data, for what purposes we may share such information, and your rights and choices with regard to controlling your personal data.
This PCP only applies to the information processed by The CPM Organization and its affiliates or any third parties acting with our authorization (collectively, "CPM", "we", "our" or "us"). It also covers information provided to us by third parties about you.
Please review our Terms of Service which governs your use of the Services, whether online or in person, including when you:
• Interact with our properties, including our vacation rentals, realty offices, brokerage, retail establishments and managed properties (“Properties”);
• Use of websites owned and controlled by CPM ("Sites");
• Use of our mobile, web, tablet, desktop and other applications, including applications made available through Facebook, iOS and Android (the “Apps”); and,
• Use of any other content, applications, features, functionality, information and services offered by us, whether through our Apps, the Sites, at our properties or otherwise (collectively our “Services”).
Any capitalized terms that are not defined in this PCP shall have the meaning ascribed in the Terms of Service.
Please note that when you visit a website operated by any of our third-party licensees, such as, developers or owners of CPM branded Properties, CPM does not control such websites and is, therefore, not responsible for those third parties’ privacy practices. This is true even though our branding may appear on those sites. Rather, you should look to those third parties’ privacy policies to know how they collect, store, use and share your information
The collection and use of your information as described in this PCP is based on our contractual obligations to you, our legitimate business interest, compliance with our legal or regulatory obligations or, where applicable, your voluntary consent. If you do not agree with the terms of this PCP, please see information about your rights below. You also have the choice not to utilize the Services.
What Personal Data Do We Process?
We process personal information or other information about you when you interact with any of our Properties, visit our Sites or otherwise use our Services. The information we may process depends upon your interaction with us. The types of personal data that we may process include the following:
• Reservations and Account Information: You may need to register for an account to access and use certain features, content or functions of the Services, for example, booking a reservation, applying for membership at one our clubs, reserving a tee-time at a golf course, making a restaurant reservation, purchasing products from the CPM Store or CPM Winery, signing up for loyalty programs or using any of our Apps. When you create an account, we will process personal data as necessary to offer and fulfill the Services you request. Depending on the Services you elect to use and only as necessary to provide such Services, we may ask you for your consent to process your name, date of birth, proof of identity (e.g., driver’s license number, security question), phone number, mailing address, email address, pet’s name, guests’ names, and login credentials (i.e., a unique user name and password or through your Facebook account). Also, when you book a reservation, we may ask for additional specific account information such as arrival and departure information, corporate account number, group or convention code, travel agent number or AAA number. If you limit our processing of this information that we obtained from you via consent, you may not be able to use all of the features of the Services.
• Additional Profile Information: We may also process descriptive information about our hotel guests, golf course members or players, customers (including prospective customers), residents and visitors so that we can best provide them with a personalized experience to fit their needs. Such information may include information or data relating to your room preferences, in-room dining preferences, CPM Attaché and other concierge services, preferred dining seating, equipment rental, leisure activities and interests, and other information as necessary to fulfill special requests made by you regarding your stay or services you request from us (e.g., health conditions that require special room accommodations or accessibility). We may also process other information associated with a guest’s stay, or a member’s, player’s, customer’s or other visitor’s use of the Services, such as the hotels where you have stayed, check-in/check-out dates, goods and services used, special requests made, observations about your service preferences (including room and vacation preferences, times of play, etc.), real estate preferences (e.g., attributes of properties you are interested in, desired neighborhoods or school districts), telephone numbers dialed and faxes, texts and telephone messages received.
• Premises Security: We may also use closed circuit television and other security measures at our properties that may capture or record images of guests and visitors in public areas of our properties. We may also use closed-circuit television and other technologies that record sound or video for loss prevention and security purposes, and the protection of our guests and visitors to our properties where permitted by law.
• Payment Information and Purchase History: If you purchase products or offerings on or through our Services (e.g., CPM Store) your payment information like your credit or debit card number, card type and expiration date and billing address . We may also use basic personal identifiers to fulfill your order and deliver the Services you requested, such as your name, date of birth and shipping address. Finally, we also process commercial information about your purchase and transaction history to improve your experience the details of any purchased services or products, including the date of purchase, rate or product purchase price, food/beverage purchase history, and any wording you may suggest for a gift card. This information may be processed by us and/or payment processors and service providers on our behalf.
• Location Information: With your permission, we may process your geographic location (GPS) if you have enabled location settings on your Device (e.g., by sharing your location with an App) or on your web browser when you visit our Sites. This information is important to provide you with directions to our properties or to determine your proximity to other features (for example, to determine yardage when playing a golf course). You can disable the settings on your Device or web browser If no longer wish to share this location information. Your Device may also automatically share some location information if you connect to WiFi or Bluetooth. You may refrain from connecting to WiFi and/or disable Bluetooth features on your Device if you would like to prevent this from happening.
• Personal Data You Choose to Provide for Marketing or Additional Services: We may process personal data that you choose to provide to us when you elect to participate in promotional opportunities through our Apps, Sites, or Services. For example, if you sign up to receive newsletters, marketing emails or other communications regarding the Services and/or promotions from our preferred third-party products or other CPM or Cygnus brands, participate in contests, surveys and other promotions related to the Services. To better serve you, we may process your name, email address, mailing address, gender, interests and phone number to provide these additional features. If any additional personal data will be processed for specific promotions, we will notify you about how that personal data will be treated.
• Comments, Feedback, Customer Service and Other Inquires: We encourage you to use the Services (e.g., completing a "Contact Us" form on our Sites or surveys relating to your hotel stay) to tell us about questions you may have, inquire about memberships, request to be contacted about properties available for sale or rent, as well as provide us with comments and or feedback about the Services. You may also have opportunities to communicate with other users of the Services and post comments to or otherwise interact with certain aspects of the Services that are available to the public and/or other users. We will process any information you submit, post or provide in the course of such activities to respond to your comments or feedback. In the event you contact one of our properties or customer call centers, we may process information related to conversations, including recording or monitoring customer service calls for quality assurance and training purposes, and to verify your identity.
• Application Information: When you apply for membership to any of our golf courses, clubs or loyalty programs, or submit an application(s) in connection with the rental or purchase of a property to our realty or brokerage service, we process information that you choose to provide to us through your application process, which may include your name, email address, mailing address, phone number, gender, date of birth, dependent information and references.
• Browsing Information, Logs, Usage Data and Other Device Information: When you visit our Sites and use our Apps, we may process information about your activities on our Sites and Apps through the use of technology such as cookies, web beacons, and other tracking technologies, as further explained in Sections 13 - 14 below. Providing this information is not mandatory and cookies can be disabled by clicking here. However, please note that our Sites and Apps may not offer the same functionalities when certain cookies are disabled.
How Do We Use the Personal Data We Process?
We may process your personal data (depending on your interaction with us) for any reason that is permitted under data protection laws in accordance with this PCP, which may include the purposes below. Note that the legal bases outlined below are required to be included under European Union (EU) data protection laws, but are not required to be included if you do not reside in the EU.
To fulfill our contractual obligations under an existing agreement with you to provide you with products and services you requested, or in anticipation of entering into such an agreement with you, including, without limitation:
To complete and fulfill your hotel reservation and stay, including, processing your payment, providing you with information relating your stay, sending you booking confirmations, cancellations, modifications or pre-arrival/post-arrival messages, and providing you with other information about the area and property in which you are going to stay;
To communicate with you about your account, transactions, applications, the Sites and the Services;
To respond to requests for information and services, including services from a third party (such as restaurants or transportation providers);
To manage, evaluate and administer applications you have submitted to us for membership and/or rental or purchase of real estate;
To fulfill orders and provide you with products and services you have requested and/or paid for, including for our accounting, auditing or other internal functions, and to offer you an overview of your transactional history;
To manage and administer your accounts, including sending you transaction-related emails for such things as account verification, purchase and billing confirmation, processing membership dues, and contacting references you provide;
To enforce your legal rights under an agreement; and
To provide you with an estimate for our products or services.
To pursue our legitimate business interests, including, without limitation:
To provide you with a more personalized level of service, including information and services related to the products and services you purchase from us, available from a trusted third party (such as on-site restaurants and spas, local attractions and transportation options);
To manage our business needs, such as monitoring, analyzing, modifying and improving our Services’, including the Sites’, functionality and performance, including changes/updates to features of the Sites/Apps, technical and security notices;
For the security and safety of our guests, members and visitors, and for purposes of fraud prevention, including preventing fraud and abuse on and unauthorized access to the Services and Sites;
To provide you with information about products and services you have purchased or indicated your interest in;
To determine which features and functionality of the Services users like best to help us operate, enhance and improve the Services, including by asking you to participate in a survey relating your use of the Services;
To respond to any customer service requests, such as resolving your problems or responding to your questions, managing any complaints or feedback you provide;
For statistical analysis of aggregated data to help us segmenting our offering and develop our Services;
To better understand the way in which our Sites and Apps are working and offer you a better Site and/or App user experience, to create statistics in relation to the use of our Sites, Apps and our Services generally;
To help us diagnose technical issues and problems related to our Services;
To grow our business, including our portfolio of CPM or Cygnus branded properties, products and services;
To get to know our potential and existing guests, members, clients, consumers, and users; and
To identify relevant content shared with potential and current users.
To comply with our regulatory and legal obligations or to enforce our legal rights, including, without limitation:
To meet reporting requirements (e.g., filing tax forms);
To retain documents and information related to a legal action;
To enforce the Terms of Service; and
To report data breaches or unauthorized access to the Services.
With your consent*, including, without limitation:
To provide location-specific functionality, features, services or offers;
To market to you by delivering marketing materials about our CPM or Cygnus brands, products and services, as well as the products and services of unaffiliated third party businesses;
To display online advertising and marketing information based on your use of the Services and other websites services and platforms that you have visited;
To provide you with tailored advertisements about our CPM or Cygnus portfolio of brands on third party websites, we may provide your personal information to Third Party Advertising Providers that combine such data with information collected by third-parties to send you advertisements on our Sites and third party websites, about our exclusive offers, brand news and events tailored to you and your interests;
To provide personalized services offered by us on third-party websites and online services;
To enable you to connect with others who use our Services; and
For other purposes for which you may grant consent.
*You can withdraw your consent at any time by following the steps in Section 7 of this PCP.
When Do We Share the Personal Information We Process?
We are committed to building relationships with third parties who are dedicated to providing you a safe and satisfying experience. We only provide such third parties with access to your information to the extent reasonably necessary for them to provide the services for which they are contractually engaged to provide. We request that all of our service providers maintain commercially reasonable standards of security and confidentiality and must agree to keep such information secure and confidential in line with this PCP.
In connection with our global operations, we may share information we collect from you or about you with some of our affiliates, licensees and third party service providers as necessary to assist us in providing the Services to you, as set forth in more detail below:
Our Group Entities: We may disclose your personal data to our group entities that are affiliates and/or subsidiaries or parents of CPM to provide you with tailored products, services and communications.
Service Providers: We may partner with other companies to help us operate certain aspects of our businesses, including the hosting of our Sites and Apps, operation of our technology infrastructure, processing of payments and reservations, and fulfillment certain of the services or products you request from us. We carefully select such third party operators, merchants, website hosts, service providers and participants to your transactions, including our on-property service providers, such as our spa operators, restaurants, valets and concierge services, for the purpose of
(1) assisting with facilitating transactions on or through the Services,
(2) providing information technology and customer service assistance, and
(3) providing, offering, supporting, administering, maintaining and enabling the Services (including providing a full range of content, activities, services, features and functions offered on or in connection with the Services).
Advertising Providers: In order to provide you with marketing and exclusive offers, including emails and advertisements tailored to you and your interests on and off the Services, we may provide your information to Third Party Advertising Providers.
Co-Sponsors of Promotions: From time to time, we may co-sponsor promotions, sweepstakes, prize draws, competitions or contests with other companies. If you enter one of these sweepstakes or contests, we may share your information with the co-sponsor or third-party sponsor.
Credit Authorization: When you submit an application for the purchase or rental of real estate, or membership at one our services, your personal information will be used and disclosed to appropriate third parties in accordance with applicable laws for the purpose of determining your credit worthiness and whether to approve your application.
Corporate Transactions or Events: We may disclose your personal data in connection with a merger, sale of substantially all of our assets or stock, joint venture, transfer, corporate reorganization or other disposition of our business.
To Fulfill Your Requests: If you elect to use certain authentication or sharing features available on the Sites or via the Services, we may use your personal data to fulfill your request to share content with or provide access to such third parties (e.g., Facebook, LinkedIn, or Twitter).
Can Children Use Our Sites and Apps?
Our Sites and our Apps are not directed to children under the age of majority. We do not knowingly collect information via our Sites and Apps from children or other individuals who are not legally able to use our Sites and/or our Apps. If we obtain actual knowledge that we have collected personal data from someone under the age of majority, we will promptly delete it unless we are legally obligated to retain such data. If you believe that we have mistakenly or unintentionally collected information from someone under the age of majority, please contact us. For users in the United States, please also visit ftc.gov for information from the Federal Trade Commission about protecting children’s privacy online.
How Will We Protect Your Personal Data?
While no data transmission over the internet or wireless networks is 100% secure from intrusion, we maintain and have implemented reasonable physical, electronic, technical and procedural security policies and measures to protect the personal data that we process, which are consistent with applicable privacy and security laws. These policies and measures are designed to prevent against loss, misuse, unauthorized access, modification and disclosure and unlawful destruction of your personal data. The security measures can change and be modified over time, but generally include, but are not limited to, firewalls, data encryption, physical access controls to our data centers, servers and hardware and information access authorization controls, regular testing and updating of the systems and training programs. While we are dedicated to securing your personal data and our systems and Services, you are responsible for securing and maintaining the privacy of your credentials (e.g., user name, password or account information) and verifying that personal data we maintain about you is accurate and current. It is your responsibility to give us current, complete, truthful and accurate information, and to keep such information up to date. We cannot and will not be responsible for any problems or liability that may arise if you do not give us accurate, truthful or complete information, or you fail to update such information. We will reject and delete any entry that we believe in good faith to be false, fraudulent or inconsistent with this PCP.
How Long Do We Keep Your Personal Data?
We access, retain, store and use personal data for the least amount of time necessary pursuant to our relationship with you (e.g., to provide you with or access to our products and services), in accordance with our data retention policies and applicable law. We do not process more personal data than is necessary to fulfill our obligations to you or at law or for purposes stated in this PCP.
What Rights and Choices Do You Have with Regard to Your Personal Data?
How to Unsubscribe from CPM/Cygnus Marketing: If you want to unsubscribe from receiving tailored advertisements on third party sites (as described in "Advertising Data" in Section 2) and/or marketing emails sent by or on behalf of CPM, you can do so by sending a message through our website or clicking on an unsubscribe link from a marketing email.
Modifying Privacy Settings: You also may be able to adjust certain privacy, permission and user account settings, by responding to request alerts or notifications on your Device or by navigating to the settings, account or privacy section (as the case may be) of your Device or the applicable Third Party Platform and limiting certain Service functionality (e.g., location services, etc.). Please be aware that if you limit the collection of certain information, you may not be able to use all of the features and functionality of the Services.
What Are Cookies?
What Types of Cookies Do We Use?
We do not place cookies until you elect to continue using our Site after our cookie banner displays.
Our cookie management tool uses Cookiepedia to, with no input from us, automatically categorize cookies that we deploy on our Sites. We use the following types of cookies:
Strictly Necessary Cookies: These cookies are necessary for the Sites to function and cannot be switched 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(s) may not work if you choose to do so.
Performance Cookies: These cookies allow us to count visits and traffic sources, so we can measure and improve the performance of our Sites. They help us know which pages are the most and least popular and see how visitors move around the Sites. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies, we will not know when you have visited our Site(s).
Functional Cookies: These cookies allow the provision of enhanced functionality and personalization, such as videos and live chats. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies, then some or all of these functionalities may not function properly.
Targeting Cookies: These cookies are set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant ads on other sites. They work by uniquely identifying your browser and Device. If you do not allow these cookies, you will not experience our targeted advertising across different websites.
What Information Is Processed By Cookies?
What Is Our Legal Basis For Processing Information Collected By Cookies?
By continuing to browse on our Site(s) you consent to us deploying cookies as described in this policy. If you do not wish to accept cookies from our Site(s), or would like to stop cookies being stored on your Device in the future, you can change your settings in our Cookie Settings.
What Other Information Should I Know?
From time to time, we may modify this PCP to reflect industry initiatives, third party requirements or changes in the law, technology, our information processing practices or the features and functionality of the Services, and such modifications shall be effective upon posting.
How Can You Contact Us?
If you have any questions or concerns about our privacy practices, how we handle your personal data or any of the terms or conditions of this PCP, please feel free to contact us at:
Message: Send us a note
Address: PO Box 991 - Suttons Bay, MI 49682
Serving all Leelanau and Grand Traverse county real estate areas including: Traverse City, Sutton’s Bay, Leland, Lake Leelanau, Glen Arbor, Old Mission, Omena, Northport, Empire, Elk Rapids and Torch Lake.
Serving all metro Denver real estate areas including: Arvada, Boulder, Broomfield, Englewood, Golden, Highlands Ranch, Lakewood, Littleton, Vail, Breckenridge and Winter Park.