How We Collect Personal Data

 

We collect Personal Data in a variety of ways:

  • Online Services. 

We collect Personal Data when you make a reservation, from our Website, communicate with us, or otherwise connect with us or post to social media pages, or sign up for a newsletter or participate in a survey, contest or promotional offer.

  • Property Visits and Offline Interactions. 

We collect Personal Data when you visit our property or use on-property services and outlets, concierge services. 

  • Customer Care Centers. 

We collect Personal Data when you make a reservation over the phone, communicate with us by email or fax.

  • Strategic Business Partners. 

We collect Personal Data from companies with whom we partner to provide you with goods, services or offers based upon your experiences at our property or that we believe will be of interest to you (“Strategic Business Partners”). Examples of Strategic Business Partners include travel and tour partners, timeshare partners, rental car providers and travel booking platforms. 

  • Physical & Mobile Location-Based Services.

We collect Personal Data if you download one of our Apps. For example, we may collect the precise physical location of your device by using satellite, cell phone tower, Wi-Fi signals, or other technologies. We will collect this data if you opt in through the App or other program (either during your initial login or later) to receive the special offers and to enable location-driven capabilities on your mobile device. If you have opted-in, the App or other program will continue to collect location data when you are in or near the property until you log off or close application (i.e., the App or other program will collect this data if it is running in the background) or if you use your phone’s or other device’s setting to disable location capabilities 

Collection of Other Data

“Other Data” are data that generally do not reveal your specific identity or do not directly relate to an individual. To the extent Other Data reveal your specific identity or relate to an individual, we will treat Other Data as Personal Data. Other Data include:

  • Browser and device data
  • App usage data
  • Data collected through cookies, pixel tags and other technologies
  • Demographic data and other data provided by you
  • Aggregated data

We collect other data in a variety of ways

  • Your browser or device.

We collect certain data through your browser or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, internet browser type and version and the name and version of the Online Services (such as the Apps) you are using. We use this data to ensure that the Online Services function properly.

  • Cookies.

We collect certain data from cookies, which are pieces of data stored directly on the computer or mobile device that you are using. Cookies allow us to collect data such as browser type, time spent on the Online Services, pages visited, referring URL, language preferences, and other aggregated traffic data. We use the data for security purposes, to facilitate navigation, to display data more effectively, to collect statistical data, to personalize your experience while using the Online Services and to recognize your computer to assist your use of the Online Services. Cookies further allow us to select which advertisements or offers are most likely to appeal to you and display them while you are using the Online Services or to send marketing emails. We also use cookies to track responses to online advertisements and marketing emails

You can choose whether to accept cookies by clicking yes on your browser at the bottom of our homepage. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Online Services. For example, we will not be able to recognize your computer, and you will need to log in every time you visit. You also will not receive advertising or other offers from us that are relevant to your interests and needs.

  • Pixel Tags and other similar technologies. 

We collect data from pixel tags (also known as web beacons and clear GIFs), which are used with some Online Services to, among other things, track the actions of users of the Online Services (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Online Services.

  • Analytics. 

We collect data through Google Analytics and Adobe Analytics, which use cookies and technologies to collect and analyze data about the use of the Services. These services collect data regarding the use of other websites, apps and online resources. We use Google Analytics and Google AdWords, services which transmit website traffic data to Google servers. Google Analytics does not identify individual users and does not associate your IP address with any other data held by Google. We use reports provided by Google to help us understand website traffic and web page usage and optimize advertisements bought from Google’s own and other advertising networks. Google may process the data in the manner described in Google’s Privacy Policy and for the purposes set out above in this section. 

Our website also uses Facebook pixel, which collects anonymized aggregated data that helps us with optimization of ad purchases on Facebook’s different platforms (including Instagram). Facebook collects a user id that will allow them to match if a user has visited a site with the Facebook pixel. We as advertisers can however never identify the behavior of a specific user. Facebook and its related platforms are in a closed advertising ecosystem where their users can regulate if they consent to advertisers using data collected from their websites to purchase ads on Facebook.

  • Your IP Address. 

We collect your IP address, a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP address is identified and logged automatically in our server log files when a user accesses the Online Services, along with the time of the visit and the pages that were visited. We use IP addresses to calculate usage levels, diagnose server problems and administer the Online Services. We also may derive your approximate location from your IP address.

Use of Personal Data and Other Data

We use Personal Data and Other Data to provide you with Services, to develop new offerings. In some instances, we will request that you provide Personal Data or Other Data to us directly. If you do not provide the data that we request, or prohibit us from collecting such data, we may not be able to provide the requested Services.

We use Personal Data and Other Data for our legitimate business interests, including the following:

Provide the Services you request. We use Personal Data and Other Data to provide Services you request, including:

To facilitate reservations, payment, send administrative information, confirmations or pre-arrival messages, to assist you with meetings and events and to provide you with other information about the area and the property at which you are scheduled to visit

To complete your reservation and stay, for example, to process your payment, ensure that your room is available and provide you with related customer service

To support our electronic receipt program. When you provide an email address in making a reservation, we use that email address to send you a copy of your bill. If you make a reservation for another person using your email address, that person’s bill will be emailed to you, as well. You can opt out of receiving your bill via email and instead receive a paper copy by contacting us.

We use Personal Data and Other Data to personalize the Services and improve your experiences, including when you contact us, visit our property or use the Online Services, to:

  • Present offers tailored to your Personal Preferences

 

  • We use Personal Data and Other Data for our legitimate business interests, including the following:

We disclose Personal Data and Other Data to other companies for the purposes described in this Privacy Statement, such as providing and personalizing the Services, communicating with you, facilitating the loyalty programs, and to accomplish our business purposes. We share your Personal Data and Other Data used for making a reservation with the applicable property to fulfill and complete your reservation.

  • Strategic Business Partners. 

We disclose Personal Data and Other Data with select Strategic Business Partners who provide goods, services and offers that enhance your experience at our property or that we believe will be of interest to you. By sharing data with these Strategic Business Partners, we are able to make personalized services and unique travel experiences available to you. This sharing enables us to provide you with a single source for purchasing packages that include travel-related services, such as rental cars and vacation packages.

  • Service Providers. 

We disclose Personal Data and Other Data to third-party service providers for the purposes described in this Privacy Statement. Examples of service providers include companies that provide website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, marketing, auditing and other services.

  • Other Uses and Disclosures

We will use and disclose Personal Data as we believe to be necessary or appropriate: (a) to comply with applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including authorities outside your country of residence and to meet national security or law enforcement requirements; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect the rights, privacy, safety or the property and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

We may use and disclose Other Data for any purpose, except where we are not allowed to under applicable law. In some instances, we may combine Other Data with Personal Data (such as combining your name with your location). If we do, we will treat the combined data as Personal Data as long as it is combined.

In addition, we are not responsible for the data collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Data you disclose to other organizations through or the Apps or our Social Media Pages.

  • Third Party Advertisers

We may use third-party advertising companies to serve advertisements regarding goods and services that may interest you when you access and use the Online Services, other websites or online services. To serve such advertisements, these companies place or recognize a unique cookie on your browser (including through the use of pixel tags).

  • Security

We seek to use reasonable organizational, technical and administrative measures to protect Personal Data. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the “Contacting Us” section, below.

  • Links to other websites

In order to anticipate your needs, our website provides links to other web sites and third parties for your convenience and information. We are not responsible for the collection, use, maintenance, sharing or disclosure of data (including personal data) by such third parties. We encourage you to contact these third parties to ask questions about their privacy practices, policies and security measures before disclosing any personal data. We recommend that you review the privacy statements and policies of linked web sites to understand how those

  •  Choices, Access and Retention

 If you no longer want to receive marketing-related emails, you may opt out by following the instructions in any such email you receive from us.

We will try to comply with your request as soon as reasonably practicable. If you opt out of receiving marketing emails from us, we may still send you important administrative messages, from which you cannot opt out.

  • Retention

We will retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Statement unless a longer retention period is required or permitted by law.

The criteria used to determine our retention periods include:

The length of time we have an ongoing relationship with you and provide the Services to you Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them)

Whether retention is advisable considering our legal position (such as, for statutes of limitations, litigation or regulatory investigations)

  • Sensitive Data

Unless specifically requested, we ask that you not send us, and you not disclose, on or through the Services or otherwise to us, any Sensitive Personal Data (e.g., social security numbers, national identification number, data related to racial or ethnic origin, political opinions, religion, ideological or other beliefs, health, biometrics or genetic characteristics, criminal background, trade union membership, or administrative or criminal proceedings and sanctions).

In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries will be entitled to access your Personal Data.

Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA

  • Marketing Preferences

We want to engage with you in a way that is meaningful to you. We recognize that you may only want to hear from us in a limited way.

You may choose to unsubscribe from our newsletters by clicking the link at the bottom of one of our communications

*Please note that even if you choose to opt-out of communications with us, we will continue to send you transactional messages about your specific reservation or stay with us, such as pre-arrival, confirmation and guest satisfaction surveys.

  • Use of Personal Data

If we intend to use your Personal Data for a purpose that is materially different from these purposes or if we intend to disclose it to a third party not previously identified, we will notify you and offer you the opportunity to opt-out of such uses and/or disclosures where it involves Personal Data or opt-in where Sensitive Personal Data is involved.

  • Privacy Policy Changes

This Policy may be changed from time to time, consistent with the requirements of the Privacy Shield. You can determine when this Policy was last revised by referring to the “LAST UPDATED” legend at the top of this page. Any changes to our Policy will become effective upon our posting of the revised Policy on the Site.