Privacy Policy


Thank you for your interest in Destination El Paso’s (“DEP”, “we,” or “us”), our websites: https://visitelpaso.com/, http://www.elpasolive.com/, http://icecreamfestep.com/, https://www.winterfestep.com/, and https://suncitycraftbeerfest.com/ (the “Sites”), downloadable software, mobile applications (including tablet applications), and other services provided by us and on which a link to this Privacy Policy is displayed, and all other communications with individuals though from written or oral means, such as email or phone (collectively, together with the Site, our “Service”).

In the following document, you will receive information about the processing of your personal data, the content and services offered on the Sites, the data controller’s data protection officer in connection with the following Sites, all owned and controlled by us:

Visit El Paso https://visitelpaso.com/
El Paso Live http://www.elpasolive.com/
El Paso Ice Cream Fest:  http://icecreamfestep.com/
WinterFest:  https://www.winterfestep.com/
Sun City Craft Beer Fest:  https://suncitycraftbeerfest.com/

This Policy is incorporated into, and is subject to, the DEP Terms of Service, located here: https://visitelpaso.com/terms-of-service/.

Table of Contents
Part A. Definitions
Part B. Your Rights
1. Right to access
2. Right to rectification
3. Right to erasure (“right to be forgotten”)
4. Right to the restriction of processing
5. Right to data portability
6. Right to object
7. Right to withdraw consent
8. Right to lodge a complaint with the supervisory authority
Part C. Information Collected
1. User Provided Information
2. Information Collected By Clients
3. “Automatically-Collected” Information
4. Integrated Services
5. Information from Other Sources
6. Third Party Tracking Code
Part D. How We Use the Information We Collect
1. Operations
2. Improvements
3. Communications
4. Cookies and Tracking Technologies
5. Analytics
6. To Whom We Disclose Information
6.1 Unrestricted Information
6.2 Service Providers
6.3 Non-Personally Identifiable Information
6.4 Law Enforcement, Legal Process, and Compliance
6.5 Change of Ownership
7. Third Party Cookies
8. Third Party Services
9. Interest-Based Advertising
10. Data Security
11. Data Retention
12. Settings
Part E. General Information
1. Data Controller Contact Information
2. Data Protection Officer Contact Information
3. Changes and Updates to this Policy
4. Effective Date

Part A. Definitions
“Client” means a customer of DEP.
“Client Data” means personal data, reports, addresses, and other files, folders or documents in electronic form that a User of the Service stores within the Service.
“Personal Data” means any information relating to an identified or identifiable natural person.
“Public Area” means the area of the Site that can be accessed both by Users and Visitors, without needing to log in.
“Restricted Area” means the area of the Site that can be accessed only by Users, and where access requires logging in.
“User” means an employee, agent, or representative of a Client, who primarily uses the restricted areas of the Site for the purpose of accessing the Service in such capacity.
“Visitor” means an individual other than a User, who uses the public area, but has no access to the restricted areas of the Site or Service.

Part B. Your Rights
1. Right to opt out
2. Right to access
3. Right to rectification
4. Right to erasure (“right to be forgotten”)
5. Right to the restriction of processing
6. Right to data portability
7. Right to object
7.1. Right to object on grounds relating to the particular situation of the data subject
7.2. Right to object to direct marketing 
8. Right to withdraw consent
9. Right to lodge a complaint with the supervisory authority

1. Right to Opt Out
If you receive commercial emails from us, you may unsubscribe at any time by following the instructions contained within the email or by sending an email to the address provided in the “Data Protection Officer Contact Information” section.

Please be aware that if you opt-out of receiving commercial email from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten (10) business days for us to process your request. Additionally, even after you opt-out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding the Service.

DEP has no direct relationship with the Client’s customers or third party whose Personal Data it may process on behalf of a Client. An individual who seeks access, or who seeks to correct, amend, delete inaccurate data or withdraw consent for further contact should direct his or her query to the Client or User they deal with directly. If the Client requests DEP to remove the data, we will respond to its request within thirty (30) days. We will delete, amend or block access to any Personal Data that we are storing only if we receive a written request to do so from the Client who is responsible for such Personal Data, unless we have a legal right to retain such Personal Data. We reserve the right to retain a copy of such data for archiving purposes, or to defend our rights in litigation. Any such request regarding Client Data should be addressed as indicated in the “Data Protection Officer Contact Information” section, and include sufficient information for DEP to identify the Client or its customer or third party and the information to delete or amend.

You may opt out from the collection of navigation information about your visit to the Site by Google Analytics by using the Google Analytics Opt-out feature.

2. Right to access

We respect your privacy rights and provide you with reasonable access to the Personal Data that you may have provided through your use of the Services. If you wish to access or amend any other Personal Data we hold about you, or to request that we delete or transfer any information about you that we have obtained from an Integrated Service, you may contact us as set forth in the “Data Protection Officer Contact Information” section. At your request, we will have any reference to you deleted or blocked in our database.

You have a right to obtain access and information under the conditions in accordance with Article 15 of the General Data Protection Regulation. This means in particular that you have the right to obtain confirmation from us as to whether we are processing your personal data. If so, you also have the right to obtain access to the personal data and the information listed in Article 15 paragraph 1 of the General Data Protection Regulation. This includes information regarding the purposes of processing, the categories of personal data that are being processed and the recipients or categories of recipients to whom the personal data has been or will be disclosed (points (a), (b) and (c) of Article 15 paragraph 1 of the General Data Protection Regulation). You can find the full extent of your right to access and information in Article 15 of the General Data Protection Regulation, which can be accessed using the following link: http://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0679.

3. Right to rectification 
You have the right to rectification under the conditions provided in Article 16 of the General Data Protection Regulation. This means in particular that you have the right to receive from us without undue delay the rectification of inaccuracies in your personal data and completion of incomplete personal data. You can find the full extent of your right to rectification in Article 16 of the GDPR, which can be accessed using the following link: http://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0679

4. Right to erasure (“right to be forgotten”)
You may update, correct, or delete your Account information and preferences at any time by accessing your Account Settings page on the Service. Please note that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so. You may decline to share certain Personal Data with us, in which case we may not be able to provide to you some of the features and functionality of the Service.

You have a right to erasure (“right to be forgotten”) under the conditions provided in Article 17 of the General Data Protection Regulation. If we have made the personal data public and are obliged to erase it, we are also obliged, taking account of available technology and the cost of implementation, to take reasonable steps, including technical measures, to inform data controllers which are processing the personal data that you have requested the erasure by such data controllers of any links to, or copy or replication of that personal data (Article 17 paragraph 2 of the General Data Protection Regulation). The right to erasure (“right to be forgotten”) does not apply if processing is necessary for one of the reasons listed in Article 17 paragraph 3 of the General Data Protection Regulation. This can be the case, for example, if processing is necessary for compliance with a legal obligation or for the establishment, exercise or defense of legal claims (points (a) and (e) of Article 17 paragraph 3 of the General Data Protection Regulation). You can find the full extent of your right to erasure (“right to be forgotten”) in Article 17 of the GDPR, which can be accessed using the following link: http://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0679

5. Right to the restriction of processing
At any time, you may object to the processing of your Personal Data, on legitimate grounds, except if otherwise permitted by applicable law. If you believe your right to privacy granted by applicable data protection laws has been infringed upon, please contact DEP’s Data Protection Officer at lmccorgary@destinationelpaso.com.

You also have a right to lodge a complaint with data protection authorities. This provision does not apply to Personal Data that is part of Client Data. In this case, the management of the Client Data is subject to the Client’s own Privacy Policy, and any request for access, correction or deletion should be made to the Client responsible for the uploading and storage of such data into the Service.

You have the right to restrict processing under the conditions provided in Article 18 of the General Data Protection Regulation. This means that you have the right to obtain from us the restriction of processing if one of the conditions provided in Article 18 paragraph 1 of the General Data Protection Regulation applies. This can be the case, for example, if you contest the accuracy of the personal data. In such a case, the restriction of processing lasts for a period that enables us to verify the accuracy of the personal data (point (a) of Article 18 paragraph 1 of the General Data Protection Regulation). Restriction means that stored personal data is marked with the goal of restricting their future processing (Article 4 paragraph 3 of the General Data Protection Regulation). You can find the full extent of your right to restriction of processing in Article 18 of the GDPR, which can be accessed using the following link: http://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0679.

6. Right to data portability
You have a right to data portability under the conditions provided in Article 20 of the General Data Protection Regulation. This means that you generally have the right to receive your personal data with which you have provided us in a structured, commonly used and machine-readable format and to transmit that data to another data controller without hindrance from us if processing is based on consent pursuant to point (a) of Article 6 paragraph 1 or point (a) of Article 9 paragraph 2 of the General Data Protection Regulation or on a contract pursuant to point (b) of Article 6 paragraph 1 of the General Data Protection Regulation and processing is carried out by automated means (Article 20 paragraph 1 of the General Data Protection Regulation). You can find information as to whether an instance of processing is based on consent pursuant to point (a) of Article 6 paragraph 1 or point (a) of Article 9 paragraph 2 of the General Data Protection Regulation or on a contract pursuant to point (b) of Article 6 paragraph 1 of the General Data Protection Regulation in the information regarding the legal basis of processing in Part D of this Policy. In exercising your right to data portability, you also generally have the right to have your personal data transmitted directly from us to another data controller if technically feasible (Article 20 paragraph 2 of the General Data Protection Regulation). You can find the full extent of your right data portability in Article 20 of the General Data Protection Regulation, which can be accessed using the following link: http://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0679

7. Right to object
You have a right to object under the conditions provided in Article 21 of the General Data Protection Regulation. At the latest, in our first communication with you, we expressly inform you of your right, as a data subject, to object. More detailed information on this is given in Part E, Sections 1 and 2 of this Policy.

7.1. Right to object on grounds relating to the particular situation of the data subject

You have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data which is based on point (e) or (f) of Article 6 paragraph 1, including profiling based on those provisions. You can find information as to whether an instance of processing is based on point (e) or (f) of Article 6 paragraph 1 of the General Data Protection Regulation in the information regarding the legal basis of processing in Part D of this Policy. In the event of an objection relating to your particular situation, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for processing which overrides your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. You can find the full extent of your right to objection in Article 21 of the General Data Protection Regulation, which can be accessed using the following link: http://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0679

7.2. Right to object to direct marketing 

When your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for such marketing, which includes profiling to the extent that it is related to such direct marketing. You can find information as to whether and to what extent personal data is processed for direct marketing purposes in the information regarding the legal basis of processing in Part D of this Policy. If you object to processing for direct marketing purposes, we will no longer process your personal data for these purposes. You can find the full extent of your right to objection in Article 21 of the General Data Protection Regulation, which can be accessed using the following link: http://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0679.

8. Right to withdraw consent
Where an instance of processing is based on consent pursuant to point (a) of Article 6 paragraph 1 or point (a) of Article 9 paragraph 2 of the General Data Protection Regulation or on a contract pursuant to point (b) of Article 6 paragraph 1 of the General Data Protection Regulation, as a data subject, you have the right, pursuant to Article 7 paragraph 3 of the General Data Protection Regulation, to withdraw your consent at any time. The withdrawal of your consent does not affect the legitimacy of the processing that occurred based on your consent until the withdrawal. We inform you of this before you grant your consent. You can find information as to whether an instance of processing is based on point (a) of Article 6 paragraph 1 or point (a) of Article 9 paragraph 2 of the General Data Protection Regulation in the information regarding the legal basis of processing in Part D of this Policy.

9. Right to lodge a complaint with the supervisory authority
You have a right to lodge a complaint with a competent supervisory authority under the conditions provided in point (f) of Article 57 paragraph 1 of the General Data Protection Regulation, and listed in Part E, Sections 1 and 2 in this Policy.


Part C. Information Collected
We collect different types of information from or through the Service. The legal bases for DEP’s processing of personal data are primarily that the processing is necessary for providing the Service in accordance with DEP’s Terms of Service and that the processing is carried out in DEP’s legitimate interests, which are further explained in the section “How We Use the Information We Collect” of this Policy. We may also process data upon your consent, asking for it as appropriate.

1. User-Provided Information
When you use the Service, as a User or as a Visitor, you may provide Personal Data and we may collect Personal Data. Examples of Personal Data include name, email address, mailing address, mobile phone number, and credit card or other billing information. Personal Data also includes other information, such as geographic area or preferences, when any such information is linked to information that identifies a specific individual. You may provide us with Personal Data in various ways on the Service. For example, when you register for an Account, use the Service, post Client Data, interact with other users of the Service through communication or messaging capabilities, or send us customer service-related requests.

We collect the following user provided information on our Sites:

Site: Visit El Paso https://visitelpaso.com/
Information Collected:
- Visitor and User Name, Email Address, Phone Number, IP Address
- Event Calendar Registration Information (includes name, address, phone number, email address, social media accounts addresses)
- Miscellaneous Forms on website (includes name, address, phone number, email address, social media accounts addresses)
- Third party advertising/tracking code

Site: El Paso Live http://www.elpasolive.com/
Information Collected:
- Miscellaneous Forms on website (includes name, address, phone number, email address, social media accounts addresses)
- Third party advertising/tracking code

Site: EL Paso Ice Cream Fest http://icecreamfestep.com/
Information Collected:
- Third party advertising/tracking code

Site: WinterFest https://www.winterfestep.com/
Information Collected:
- Third party advertising/tracking code

Site: Sun City Craft Beer Fest https://suncitycraftbeerfest.com/
Information Collected:
- Third party advertising/tracking code

2. Information Collected By Clients
A Client or User may store or upload into the Service Client Data. DEP has no direct relationship with the individuals whose Personal Data it hosts as part of Client Data. Each Client is responsible for providing notice to its customers and third persons concerning the purpose for which Client collects their Personal Data and how this Personal Data is processed in or through the Service as part of Client Data.

3. “Automatically-Collected” Information
When a User or Visitor uses the Service, we may automatically record certain information from the User’s or Visitor’s device by using various types of technology, including cookies, “clear gifs” or “web beacons.” This “automatically collected” information may include IP address or other device address or ID, web browser and/or device type, the web pages or sites visited just before or just after using the Service, the pages or other content the User or Visitor views or interacts with on the Service, and the dates and times of the visit, access, or use of the Service. We also may use these technologies to collect information regarding a Visitor or User’s interaction with email messages, such as whether the Visitor or User opens, clicks on, or forwards a message. This information is gathered from all Users and Visitors.

4. Integrated Services
You may be given the option to access or register for the Service through the use of your user name and passwords for certain services provided by third parties (each, an “Integrated Service”), such as through the use of your Google account, or otherwise have the option to authorize an Integrated Service to provide Personal Data or other information to us. By authorizing us to connect with an Integrated Service, you authorize us to access and store your name, email address(es), date of birth, gender, current city, profile picture URL, and other information that the Integrated Service makes available to us, and to use and disclose it in accordance with this Policy. You should check your privacy settings on each Integrated Service to understand what information that Integrated Service makes available to us, and make changes as appropriate. Please review each Integrated Service’s terms of use and privacy policies carefully before using their services and connecting to our Service.

5. Information from Other Sources
We may obtain information, including Personal Data, from third parties and sources other than the Service, such as our partners, advertisers, credit rating agencies, and Integrated Services. If we combine or associate information from other sources with Personal Data that we collect through the Service, we will treat the combined information as Personal Data in accordance with this Policy.

6. Third Party Tracking Code
The third party tracking code works by the inclusion of a block of JavaScript code on pages in our Sites. When users to our Sites view a page, this JavaScript code references a JavaScript file which then executes the tracking operation for Analytics. The tracking operation retrieves data about the page request through various means and sends this information to the Analytics server via a list of parameters attached to a single-pixel image request.

Part D. How We Use the Information We Collect

1. Operations
We use the information – other than Client Data - to operate, maintain, enhance and provide all features of the Service, to provide the services and information that you request, to respond to comments and questions and to provide support to users of the Service. We process Client Data solely in accordance with the directions provided by the applicable Client or User.

2. Improvements
We use the information to understand and analyze the usage trends and preferences of our Visitors and Users, to improve the Service, and to develop new products, services, feature, and functionality. Should this purpose require DEP to process Client Data, then the data will only be used in anonymized or aggregated form.

3. Communications
We may use a Visitor’s or User’s email address or other information – other than Client Data – to contact that Visitor or User (i) for administrative purposes such as customer service, to address intellectual property infringement, right of privacy violations or defamation issues related to the Client Data or Personal Data posted on the Service or (ii) with updates on promotions and events, relating to products and services offered by us and by third parties we work with. You have the ability to opt-out of receiving any promotional communications as described in this Policy.

4. Cookies and Tracking Technologies
We use automatically collected information and other information collected on the Service through cookies and similar technologies to: (i) personalize our Service, such as remembering a User’s or Visitor’s information so that the User or Visitor will not have to re-enter it during a visit or on subsequent visits; (ii) provide customized advertisements, content, and information; (iii) monitor and analyze the effectiveness of Service and third-party marketing activities; (iv) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and (v) track your entries, submissions, and status in any promotions or other activities on the Service. You can obtain more information about cookies by visiting http://www.allaboutcookies.org.

5. Analytics
We use Google Analytics to measure and evaluate access to and traffic on the Public Area of the Site, and create user navigation reports for our Site administrators. Google operates independently from us and has its own privacy policy, which we strongly suggest you review. Google may use the information collected through Google Analytics to evaluate Users’ and Visitors’ activity on our Site. For more information, see Google Analytics Privacy and Data Sharing. We take measures to protect the technical information collected by our use of Google Analytics. The data collected will only be used on a need to know basis to resolve technical issues, administer the Site and identify visitor preferences; but in this case, the data will be in non-identifiable form. We do not use any of this information to identify Visitors or Users.

6. To Whom We Disclose Information
Except as described in this Policy, we will not intentionally disclose the Personal Data or Client Data that we collect or store on the Service to third parties without the consent of the applicable Visitor, User or Client. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:

6.1 Unrestricted Information
Any information that you voluntarily choose to include in a Public Area of the Service, such as a public profile page, will be available to any Visitor or User who has access to that content.

6.2 Service Providers
We work with third party service providers who provide website, application development, hosting, maintenance, and other services for us. These third parties may have access to, or process Personal Data or Client Data as part of providing those services for us. We limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and our contracts with them require them to maintain the confidentiality of such information.

6.3 Non-Personally Identifiable Information
We may make certain automatically-collected, aggregated, or otherwise non-personally-identifiable information available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding our Clients’, Users’ and Visitors’ interests, habits, and usage patterns for certain programs, content, services, and/or functionality available through the Service.

6.4 Law Enforcement, Legal Process, and Compliance
We may disclose Personal Data or other information if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a facially valid court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.

We also reserve the right to disclose Personal Data or other information that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the Service and any facilities or equipment used to make the Service available, or (v) protect our property or other legal rights, enforce our contracts, or protect the rights, property, or safety of others.

6.5 Change of Ownership
Information about Users and Visitors, including Personal Data, may be disclosed and otherwise transferred to an acquirer, successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets and only if the recipient of the User or Visitor Data commits to a Privacy Policy that has terms substantially consistent with this Privacy Policy.

Client Data may be physically or electronically transferred to an acquirer, or successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets, for the sole purpose of continuing the operation of the Service, and only if the recipient of the Client Data commits to a Privacy Policy that has terms substantially consistent with this Privacy Policy.

7. Third Party Cookies
Operators of websites and online services must disclose whether other third parties may collect personally identifiable information about an individual’s online activities from their site or service. We allow third parties to have a separate agreement to use cookies and other technologies to collect information about your use of the Site. These third parties include (1) business partners, which collect information when you view or interact with one of their advertisements on the Site; and (2) advertising networks, which collect information about your interests when you view or interact with one of their advertisements.

The information gathered by these third parties is used to make predictions about your interests or preferences so that they can display advertisements or promotional material on this Site and on other sites across the Internet tailored to your apparent interests.

The business partners and advertising networks that serve interest-based advertisements on the Services have limited access to a small amount of information about your profile and your device, which is necessary to serve you advertisements that are tailored to your apparent interests. It is possible that they may reuse this small amount of information on other sites or services.

We do not share with these third parties any information that would readily identify you (such as email address); however, these third parties may have access to information about your device (such as IP or MAC address). We do not have access to, or control over, the technologies that these third parties may use to collect information about your interests, and the information practices of these third parties are not covered by this Privacy Notice. Other than as discussed in this document, we have no control over these third parties.

The Following Types of Cookies Are Used in the Site:
- strictly necessary/essential cookies - These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies services you have asked for cannot be provided. These cookies don’t collect information that identifies a visitor.
- performance cookies - These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works.
- functionality cookies - These cookies allow the website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. For instance, a website may be able to provide you with local weather reports or traffic news by storing in a cookie the region in which you are currently located. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymized and they cannot track your browsing activity on other websites.
- behaviorally targeted advertising cookies - These cookies are used to deliver adverts more relevant to you and your interests They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaigns. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organizations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organization.

8. Third Party Services
The Service may contain features or links to web sites and services provided by third parties. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through the Service. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the Service. We encourage you to learn about third parties’ privacy and security policies before providing them with information.

9. Interest-Based Advertising
Interest based advertising is the collection of data from different sources and across different platforms in order to predict an individual’s preferences or interest and to deliver to that individual, or his/her computer, smart phone or tablet, advertising based on his/her assumed preference or interest inferred from the collection of data pertaining to that individual or others who may have a similar profile or similar interests.

We work with a variety of third parties to attempt to understand the profiles of the individuals who are most likely to be interested in the DEP products or services so that we can send them promotional emails, or serve our advertisements to them on the websites and mobile apps of other entities.

These third parties include: (a) advertising networks, which collect information about a person’s interests when that person views or interacts with one of their advertisements; (2) attribution partners, which measure the effectiveness of certain advertisements; and (3) business partners, which collect information when a person views or interacts with one of their advertisements.

In collaboration with these third parties, we collect information about our customers, prospects and other individuals over time and across different platforms when they use these platforms or interact with them. Individuals may submit information directly on our Sites or on platforms run by third parties, or by interacting with us, our advertisements, or emails they receive from us or from third parties. We may use special tools that are commonly used for this purpose, such as cookies, beacons, pixels, tags, mobile advertising IDs, flash cookies, and similar technologies. We may have access to databases of information collected by our business partners.

The information we or third party collect enables us to learn what purchases the person made, what ads or content the person sees, on which ads or links the person clicks, and other actions that the person takes on our Sites, or in response to our emails, or when visiting or using third parties’ platforms.

We, or the third parties with which we work, use the information collected as described above to understand the various activities and behaviors of our customers, Site visitors and others. We, or these third parties, do this for many reasons, including: to recognize new or past visitors to our Sites; to present more personalized content; to provide more useful and relevant ads - for example, if we know what ads you are shown we can try not to show you the same ones repeatedly; to identify visitors across devices, sales channels, third party websites and Sites, or to display or send personalized or targeted ads and other custom content that is more focused on a person’s perceived interest in products or services similar to those that we offer.

Our interest-based ads may be served to you in emails or on third-party platforms. We may serve these ads about our products or services or send commercial communications directly ourselves or through these third parties.

Visitors may opt out of receiving interest based advertising by advertising networks that may be delivered to them on our platform and other websites by visiting the following websites: http://www.aboutads.info/consumers; and http://www.networkadvertising.org. These features will opt a Visitor out of many – but not all - of the interest-based advertising activities in which we or third parties engage.

10. Data Security
We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. We maintain appropriate administrative, technical and physical safeguards to protect Personal Data against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Data in our possession. This includes, for example, firewalls, password protection and other access and authentication controls. We use SSL technology to encrypt data during transmission through public internet, and we also employ application-layer security features to further anonymize Personal Data.

However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We cannot ensure or warrant the security of any information you transmit to us or store on the Service, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If you believe your Personal Data has been compromised, please contact us as set forth in the “How to Contact Us” section.

If we learn of a security systems breach, we will inform you and the authorities of the occurrence of the breach in accordance with applicable law.

11. Data Retention
We only retain the Personal Data collected from a User for as long as the User’s account is active or otherwise for a limited period of time as long as we need it to fulfill the purposes for which we have initially collected it, unless otherwise required by law.

12. Settings
Although we may allow you to adjust your privacy settings to limit access to certain Personal Data, please be aware that no security measures are perfect or impenetrable. We are not responsible for circumvention of any privacy settings or security measures on the Service. Additionally, we cannot control the actions of other users with whom you may choose to share your information. Further, even after information posted on the Service is removed, caching and archiving services may have saved that information, and other users or third parties may have copied or stored the information available on the Service. We cannot and do not guarantee that information you post on or transmit to the Service will not be viewed by unauthorized persons.

Part E. General Information

1. Data Controller Contact information

Organization: Destination El Paso
Address: One Civic Center Plaza
City, State, Zip: El Paso, Texas 79901
Telephone: (915) 534-0600
Fax: (915) 534-0687
E-Mail: info@destinationelpaso.com

2. Data Protection Officer Contact Information
If you have any questions, concerns, or complaints about this Policy or your Personal Data, our use and disclosure practices, or your consent choices, please contact DEP’s Data Protection Officer as follows:

Name: Leesy McCorgary
Organization: Destination El Paso
Address: One Civic Center Plaza
City, State, Zip: El Paso, Texas 79901
Telephone: (915) 534-0600
Fax: (915) 534-0687
E-Mail: lmccorgary@destinationelpaso.com

3. Changes and Updates to this Policy
It may be necessary to amend this Privacy Policy due to technical developments and/or changes to statutory or regulatory requirements. The currently valid version of this Privacy Policy can be accessed at any time at:

Visit El Paso https://visitelpaso.com/privacy-policy/
El Paso Live http://www.elpasolive.com/privacy-policy/
El Paso Ice Cream Fest:  http://icecreamfestep.com/privacy-policy/
WinterFest:  https://www.winterfestep.com/privacy-policy/
Sun City Craft Beer Fest:  https://suncitycraftbeerfest.com/privacy-policy/

Your continued use of the Service after the revised Policy has become effective indicates that you have read, understood and agreed to the current version of the Policy.

4. Effective Date
The effective date of this Privacy Policy is August 22, 2018.