Privacy Policy

Effective Date: 03/01/2026

SCOPE

This Privacy Policy (“Policy”) describes how TSTRC Holdco, LLC dba Avari Management, its subsidiaries and affiliates (collectively, “Avari,” “we,” or “us”) treats personal information that we collect offline and through our websites and other online platforms where this Policy is located (collectively, our “Platform”). This Policy does not apply to our collection of employment-related information.

NOTICE AT COLLECTION

We collect information from you and about you. Here are some examples of the information we may collect, how we may use it, how we may disclose it and whether we share it for cross-contextual advertising purposes (“sharing”) or sell it. Below this Notice At Collection, you will find more detailed descriptions of how we may collect, use and disclose personal information.

• Contact and Identity Information. This may include your name, mailing or billing address, email address, phone number, signature, physical characteristics or description. We may also collect names and contact information that you provide about other renters or guests as well as your license plate number and information about your car.
  • How We May Collect It: Directly from you; passively or from third parties.
  • How We May Use It: To run and improve our business; to complete transactions; to communicate with you; to understand your interests; to determine your eligibility; for marketing purposes; to combine information; for security purposes; as otherwise permitted by law or as we may notify you; as requested or directed by you.
  • How We May Disclose It: Internally; on our Platform; with our service providers; with our business partners; with any successors to all or part of our business; to comply with the law or to protect ourselves; for other reasons we may describe to you; as requested or directed by you.
  • We may share this information with advertising networks and affiliates. For more information about your right to opt-out, please click here.
• Government identification numbers. This may include your Social Security number, driver’s license or state identification number, passport number, military identification number, or tribal identification number.
  • How We May Collect It: Directly from you.
  • How We May Use It: To run and improve our business; to complete transactions; to make payments to you; to determine your eligibility; to combine information; for security purposes; for tax or licensing purposes; as otherwise required or permitted by law; as we may notify you; as requested or directed by you.
  • How We May Disclose It: Internally; with our service providers; with our business partners; with any successors to all or part of our business; to comply with the law or to protect ourselves; for other reasons we may describe to you; as requested or directed by you.
  • We Do Not Share or Sell This Information.
• Financial information. This may include your credit or debit card number, or your checking or savings account number.
  • How We May Collect It: Directly from you or from third parties.
  • How We May Use It: To run and improve our business; to complete transactions; to make payments to you; to determine your eligibility; to combine information; for tax or licensing purposes; as otherwise required or permitted by law; as we may notify you; as requested or directed by you.
  • How We May Disclose It: Internally; with our service providers; with our business partners; with any successors to all or part of our business; to comply with the law or to protect ourselves; for other reasons we may describe to you; as requested or directed by you.
  • We Do Not Share or Sell This Information.
• Protected classification characteristics under state or federal law. This may include your race, color, ancestry, national origin, citizenship, religion or creed, marital status, physical or mental disability, age, sex, sexual orientation, veteran or military status or genetic information.
  • How We May Collect It: Directly from you or from third parties.
  • How We May Use It: To run and improve our business; to determine your eligibility; to combine information; for security purposes; as otherwise permitted by law or as we may notify you; as requested or directed by you.
  • How We May Disclose It: Internally; with our service providers; with our business partners; with any successors to all or part of our business; to comply with the law or to protect ourselves; for other reasons we may describe to you; as requested or directed by you.
  • We Do Not Share or Sell This Information.
• Commercial information and information you submit. This may include information that could identify you and relates to the properties or services in which you are interested or have considered. We may also collect personal information about your consuming history or tendencies, including your travel preferences. This may any information that you voluntarily submit on the Platform, such as a review, comment, or question.
  • How We May Collect It: Directly from you; passively or from third parties.
  • How We May Use It: To run and improve our business; to communicate with you; to understand your interests; to determine your eligibility; for marketing purposes; to combine information; for security purposes; as otherwise permitted by law or as we may notify you; as requested or directed by you.
  • How We May Disclose It: Internally; on our Platform; with our service providers; with our business partners; with any successors to all or part of our business; to comply with the law or to protect ourselves; for other reasons we may describe to you; as requested or directed by you.
  • We may share this information with advertising networks and affiliates. For more information about your right to opt-out, please click here.
• Internet or other similar network activity. This may include unique personal identifier, online identifier, IP address, device identifier, browsing history, search history, and information regarding interaction with an Internet website, application, or advertisement. This may also include information about the browser you are using or what site you came from and what site you visit when you leave us. It may also include information relating to your general location based on your IP address.
  • How We May Collect It: Directly from you; passively or from third parties.
  • How We May Use It: To run and improve our business; to communicate with you; to understand your interests; to determine your eligibility; for marketing purposes; to combine information; for security purposes; as otherwise permitted by law or as we may notify you; as requested or directed by you.
  • How We May Disclose It: Internally; on our Platform; with our service providers; with our business partners; with any successors to all or part of our business; to comply with the law or to protect ourselves; for other reasons we may describe to you; as requested or directed by you.
  • We may share this information with advertising networks and affiliates. For more information about your right to opt-out, please click here.
• Inferences drawn from other personal information. This may include a profile relating to your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitude.
  • How We May Collect It: Directly from you; passively or from third parties.
  • How We May Use It: To run and improve our business; to communicate with you; to understand your interests; to determine your eligibility; for marketing purposes; to combine information; for security purposes; as otherwise permitted by law or as we may notify you; as requested or directed by you.
  • How We May Disclose It: Internally; on our Platform; with our service providers; with our business partners; with any successors to all or part of our business; to comply with the law or to protect ourselves; for other reasons we may describe to you; as requested or directed by you.
  • We may share this information with advertising networks and affiliates. For more information about your right to opt-out, please click here.

Our Personal Information Retention Criteria: The California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, “CCPA”) requires that we disclose the criteria we use to determine how long we will retain each category of personal information we collect. Oftentimes, our records contain several of these categories of personal information combined together and therefore we consider, on a case-by-case basis, a number of factors to assess how long personal information is retained. These factors include what personal information is reasonably necessary to (i) provide our products and services or administer our relationship with an individual; (ii) protect our business, employees, organization and others; (iii) fulfill our legal and regulatory obligations; and (iv) investigate and address issues which may include safety concerns, potential security incidents or policy violations.

HOW WE MAY COLLECT YOUR PERSONAL INFORMATION

We may collect your personal information in different ways. Below, you will find additional details and examples regarding how we may collect your personal information.

• Directly From You. For example:
  • Register for an account.
  • Make a reservation or complete a transaction.
  • Create a wishlist of properties.
  • Submit an inquiry or other information to us.
  • Sign-up for one of our events.
  • Enter a contest or promotion.
  • Complete an online form.
  • Contact our sales or support team.
  • Interact with our social media pages.
  • Otherwise engage with us.
• Passively. For example, when you visit and navigate our Platform on any device. We may also collect information about users over time and across different websites and devices when you use the Platform. We may use tools such as analytics and cookies, including those run by third parties, to collect this information.
• From Third Parties. We may receive information about you from other sources. For example, this may include receiving information from:
  •  Our business partners, including analytics vendors and advertising networks.
  • Social media sites, including Facebook, Twitter, YouTube, LinkedIn, and Instagram.
  • Your contacts who provide your information to us because they think you may be interested in our products and services or they want to share a product or service with you. This includes renters who provide us with information about other guests on a reservation.
  • Companies that provide information to supplement what we already know about you, including data aggregators. Certain third parties may link your name and email address to other information they have collected. This might include online usage information.

HOW WE MAY USE YOUR PERSONAL INFORMATION

Here are more details and examples regarding how we may use your personal information:

• To Run and Improve Our Business. We may use your information to make our Platform and our products and services better. This may include using your information to list your property, complete reservations, and provide related services. It may also include using your information for business administration purposes, such as for accounting, record keeping, legal, backup and other administrative purposes.
• To Communicate With You. This may include responding to your feedback or providing customer support. It may also include responding to your inquiries and questions. We may communicate with you about your account or our relationship. We may also contact you about this Policy or our Platform terms and conditions.
• To Understand Your Interests. This may include understanding what properties, products, and services may be of interest to you. This may also include customizing your experience with us.
• To Determine Your Eligibility. This may include evaluating your eligibility for our products and services. It may also include determining your eligibility for contests and promotions.
• For Marketing Purposes. We may provide you with information about our company, our products and services, or specific offers for you. This includes using your information to personalize your experience on our Platform and with our products. We may also engage in cross-contextual advertising and retargeting. For more information about your choices related to these communications, see the Choices section below.
• To Combine Information. For example, we may combine information that we collect offline with information we collect through our Platform. We may also combine information we collect about you from the different devices you use to access our Platform.
• As Required By Applicable Law. This may include meeting local or state requirements requiring that we collect proof of identity and/or age in connection with a reservation.
• For Security Purposes. This could include protecting our company and consumers who use our products and services. It may also include protecting our Platform. This may include conducting internal security investigations and cooperating with criminal investigations.
• As Otherwise Permitted By Law or As We May Notify You.
• As Requested or Directed By You.

HOW WE MAY DISCLOSE YOUR PERSONAL INFORMATION

Here are more details and examples regarding how we may disclose your personal information:

• Internally. We may disclose your information to our parent, subsidiary, and affiliate entities.
• On Our Platform. For example, we may disclose your information on our Platform or on our social media sites.
• With Our Service Providers. We may disclose your information with third parties who perform services on our behalf. For example, this may include companies that send emails on our behalf or help us run our Platform.
• With Our Business Partners. For example, we may also disclose personal information with social media sites, advertisers, media buying agencies, advertising networks and advertising service providers for the purposes described in this Policy. We may also disclose personal information with companies that help us learn more about our customers.
• With Property Owners, Managers, and Housing Associations. We may disclose your information to property owners, managers, and housing associations as necessary to comply with applicable laws and contracts.
• With Any Successors to All or Part of Our Business. For example, if we merge with, are acquired by, or sell part of our business to another entity. This may include an asset sale, corporate reorganization or other change of control.
• To Comply With the Law or To Protect Ourselves. For example, this could include responding to a court order or subpoena. It could also include sharing information if a government agency or investigatory body requests. We might disclose information when we are investigating a potential fraud.
• For Other Reasons We May Describe to You.
• As Requested or Directed By You.

YOUR PRIVACY RIGHTS

Based on your state or country of residence, you may have the rights listed below with respect to the personal information that we maintain about you. We may take steps to verify your identity, as permitted or required under applicable law, before we process your request. Verification may include asking you to provide information about yourself that we can match against information already in our possession.

Please note that we do not knowingly sell or share the personal information of consumers under 16 years.

• Notice. This means that you can request that we disclose what personal information we have collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we have disclosed personal information, and the specific pieces of personal information we have collected about the consumer.
• Transfer. This means that you may request the transfer of your personal information to a third party.
• Deletion. This means that you can request that we delete personal information about you which we have collected from you.
• Correction. This means that you can request that we correct inaccurate personal information that we maintain about you.
• Object. This means that you can object to the processing of your personal information where you feel it impacts your fundamental rights and freedoms.
• Limit. This means that you may ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have submitted an objection request that we have not yet processed.
• Opt-Out of Sale of Personal Information. If you would like to opt out of allowing us to “sell” your personal information, please follow the instructions below. We do not knowingly “sell” any personal information, including any personal information relating to consumers under the age of 16, as we understand that term to be defined under applicable law.
• Opt-Out of Sharing of Personal Information. You may have the right to opt out of sharing of personal information with third parties for cross-contextual marketing purposes. If you would like to limit the cookies and other tracking tools used on our on Platform, please make a selection using the consent management tool present on the Platform. Our Platform is capable of processing certain opt-out preference signals, including Global Privacy Controls. If you would like to implement opt-out preference signals, please review your browser configurations.
• Limit the Use or Disclosure of Sensitive Personal Information. Some laws classify certain personal information as sensitive personal information. If you are a California resident, you may have the right to request that we limit the use or disclosure of this sensitive personal information. In certain states, if you gave us consent to process this sensitive personal information, you may have the right to revoke this consent. If you submit a request, please note that this does not impact how we use or disclose your sensitive personal information prior to processing your request. We do not process sensitive personal information except for those purposes of providing our services and as necessary to comply with applicable law.
• Right to Non-Discrimination. This means that we are prohibited from discriminating against you if you exercise your rights under applicable law.

If you wish to exercise your rights under this section, you can contact us at privacy@avarimgmt.com. Please include your name, email address, and state of residence, and indicate you are making a “Privacy Rights” request. If we deny your rights request and you would like to appeal, you may contact us at privacy@avarimgmt.com.

Agents. Agents that you have authorized to act on your behalf may also submit privacy requests as instructed above. The agent must also provide evidence that they have your written permission to submit a request on your behalf. If we are unable to verify the authenticity of a request, we may ask you for more information or may deny the request. 

Additional Information for California Residents. If you reside in California, you have the right to ask us one time each year if we have shared personal information with third parties for their direct marketing purposes. To make a request, please send us an email at privacy@avarimgmt.com. Indicate in your email or letter that you are a California resident making a “California Shine the Light” inquiry. 

Complaints. Should you wish to report a complaint or if you feel that we have not addressed your concern in a satisfactory manner, you may contact the supervisory authority of your country. For a list of EU supervisory authorities, please refer here. If you live in the United Kingdom, you may contact the Information Commissioner’s Office here.

NOTICE OF FINANCIAL INCENTIVES

We may offer various financial incentives in relation to our products and services. For example, we may provide discounts, coupons and other benefits for customers who join our loyalty program or sign up for a coupon. When you participate in a financial incentive, we collect personal information from you. You have the ability to opt out of the financial incentive, or our subsequent use of your personal information in connection with a financial incentive, at any time by contacting us at privacy@avarimgmt.com. The value of your personal information is reasonably related to the value of the offer or discount presented to you. In some instances, or for some programs, we may provide you with additional terms or conditions relating to a financial incentive.

CHILDREN UNDER 18

The Platform where this Policy is located is meant for adults. We do not knowingly collect personally identifiable data from persons under the age of 18 and strive to comply with the provisions of COPPA (The Children’s Online Privacy Protection Act). If you are a parent or legal guardian and think your child under 18 has provided us with information, please contact us at privacy@avarimgmt.com. You can also write to us at the address listed at the end of this website Policy. Please mark your inquiries “COPPA Information Request.” Parents, you can learn more about how to protect children’s privacy on-line here.

COOKIES AND ELECTRONIC COMMUNICATIONS

You have certain choices about how we collect, use and disclose your information in connection with our use of cookies and our provision of electronic communications. Certain choices you make are browser and device specific.

Cookies & Other Tracking Technologies:

• Cookies: You can adjust your browser to control cookies to require your affirmative acceptance for new cookies, automatically reject cookies and/or delete or disable existing cookies. How you do so depends on the type of cookie and the browser that you are using. For more information on how to control browser cookies, click here. If information about your browser is not available through this page, please search your browser for instructions about how to opt-out of cookie collection.
• Google Analytics: We may use Google Analytics on our Platform to help us understand how you use our Platform. You can learn about how to opt-out of Google Analytics here.
• Social Media: We may use cookies or pixels from social media platforms to help us understand how you use our Platform or to target ads to you. For example, these may include cookies or pixels from YouTube, Meta, Instagram, LinkedIn, X, and TikTok. For more information about how to control tracking from these platforms, please click the provided links.
• Email Tools: You can also change your email settings to block the automatic download of images in email messages, as such images may contain technologies that help us understand how you interact with the message.
• Note that deleting or blocking cookies may impact your experience on our website, as some features may not be available. Certain options you select are browser and device specific.

Our Do Not Track Policy: 

Some browsers have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to “do not track” signals. If you block cookies, certain features on our sites may not work. If you block or reject cookies, not all of the tracking described here will stop. 

Marketing Communications:

You can opt out of receiving our marketing communications, which we may send by email or text message. Note that you will still receive transactional messages from us, including information about your account and responses to your inquiries. 

SMS Messages:

If you sign up to receive text message updates, or contact us by text message, we may send you SMS messages. Note that message and data rates may apply. The frequency of messages may vary and depend on your engagement or inquiry. You may reply “HELP” if you need assistance of “STOP” to stop receiving SMS messages. If you opt out, we may send you a confirmation SMS message to acknowledge your request.

No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All other categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties

SECURITY

The Internet is not 100% secure. We cannot promise that your use of our Platform will be completely safe. We encourage you to use caution when using the Internet. We use reasonable means to safeguard personal information under our control. A username and a password may be needed to access certain areas of our Platform. It is your responsibility to protect your username and password.

STORAGE AND TRANSFER OF INFORMATION

Information we maintain may be stored in or outside of the United States. If you live outside of the United States, you understand and agree that we may transfer your personal information to the United States. This Platform is subject to the laws of the United States, which may not provide the same level of protections as those in your own country. Personal information processed and stored in another country, including the United States, may be subject to disclosure or access requests by the governments, courts or law enforcement or regulatory agencies in that country according to its laws. By using our Platform or by providing us with personal information, you consent to any such transfer of information outside of your country.

LINKS

Our Platform may contain links to other third-party sites that are not governed by this Policy. If you click on a link to a third-party site, you will be taken to a site we do not control. We are not responsible for these third-party sites or their privacy practices. We suggest that you read the privacy policies of those sites carefully. 

HOW TO CONTACT US

If you have any questions, comments or concerns with respect to our privacy practices or this Policy, or wish to update your information, please feel free to contact us at privacy@avarimgmt.com. You may also write to us at the following address:

1675 W Redstone Center Dr, 

STE 150, PMB 5, 

Park City, UT, 84098

 

Re: Avari Privacy Policy

CHANGES IN POLICY

From time to time, we may change our Policy. If you have provided us with your email address, we will notify you of any material changes to our Policy as required by law. We will also post an updated copy on our Platform. Please check our Platform periodically for updates.