Sterling Valley Systems, Inc. Privacy Policy

Sterling Valley Systems, Inc., doing business as “Inntopia,” is a leading provider of travel reservation technology to the destination travel market. Inntopia respects our customers’ privacy and values the trust our customers place in us. Your information is used in a confidential manner and will not be sold or disclosed to any third party except as is required to process your purchase through our system as defined below. Inntopia collects your data when you make a reservation through one of our partner web sites or call centers.

What We Collect and How We Use It

We collect personal information necessary to fulfill your purchase, which could include but is not limited to the following data:

We use this data to process your purchase of travel products, goods, or services; collect or refund payment; cancel or modify a reservation; perform testing and Quality Assurance functions to improve our software; and, to perform back-office business functions related to accounting, billing, and auditing. Inntopia discloses your personal information to our travel suppliers with whom you have purchased lodging, activities, or other goods and services, and to third party agents and service providers acting on their behalf to process your order.

European Safe Harbor Policy

The Safe Harbor Privacy Policy (the “Policy”) describes the privacy principles Inntopia follows with respect to transfers of personal information from the European Union (EU) and Switzerland to the United States. For personal information of customers Inntopia receives from the European Economic Area and from Switzerland, Inntopia has committed to handling such personal information in accordance with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework.

Scope

This privacy policy applies to all personal information received by Inntopia whether in electronic, paper, or verbal format including name, address, telephone number, credit card data, email address, etc.

Principles

Inntopia’s privacy principles in this Policy have been developed based on the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework.

  1. Notice. When Inntopia collects your personal information, we’ll give you timely and appropriate notice describing what personal information we’re collecting, how we’ll use it, and the types of third parties with whom we may share it.
  2. Choice. We’ll give you choices about the ways we use and share your personal information, and we’ll respect the choices you make.
  3. Relevance. We’ll collect only as much personal information as we need for specific, identified purposes, and we won’t use it for other purposes without obtaining your consent.
  4. Retention. We’ll keep your personal information only as long as we need it for the purposes for which we collected it, or as permitted by law.
  5. Accuracy. We’ll take appropriate steps to make sure the personal information in our records is accurate.
  6. Access. We’ll provide ways for you to access your personal information, as required by law, so you can correct inaccuracies.
  7. Security. We’ll take appropriate physical, technical, and organizational measures to protect your personal information from loss, misuse, unauthorized access or disclosure, alteration, and destruction.
  8. Sharing. Except as described in this policy, we won’t share your personal information with third parties without your consent.
  9. International Transfer. If we transfer your personal information to another country, we’ll take appropriate measures to protect your privacy and the personal information we transfer.
  10. Enforcement. We’ll regularly review how we’re meeting these privacy promises, and we’ll provide an independent way to resolve complaints about our privacy practices.
Amendments

This privacy policy may be periodically consistent with the requirements of the Safe Harbor. We will post notice of any revised policy on www.inntopia.com in a timely manner.

Access to information and Dispute Resolution

To access your information, ask questions about our privacy practices, or issue a complaint, please contact Inntopia at the address below. We will attempt to resolve any disputes or concerns regarding the sharing or handling of your personal information in accordance with the principles outlined in this policy. If we are unable to resolve disputes between Inntopia and the complainant,
we have committed to participate in the dispute resolution procedures of the Federal Trade Commission and the European Data Protection Authorities to resolve disputes pursuant to the Safe Harbor Principles. For Human Resource data, Sterling Valley Systems, Inc will cooperate and comply with the Swiss Federal Data Protection and Information Commissioner (FDPIC).

Contact Information:
Inntopia Privacy Officer
PO Box 309
Stowe, VT
05672
Or by e-mail:
privacy@inntopia.com
Effective Date: May 30, 2013