2. The Application of this Policy
This Policy applies to personal information regarding guests and the other individuals with whom we do business or who visit us and to the use of that personal information in any form – whether oral, electronic or written. This Policy gives effect to our commitment to protect your personal information and has been adopted by all of the separate and distinct legal entities that manage, operate, franchise, license, own and/or provide services to Luxury Hotels Group.
This Policy is intended to describe the broadest range of our personal information processing activities and our internal policies and/or practices reflect the requirements of English Law.
3. Types of Personal Information We Collect
The term “personal information” in this Policy refers to information that identifies, or is capable of identifying, you as an individual. The types of personal information that we process include:
- Your name, gender, personal and work contact details, business title, date and place of birth, image, nationality, and passport and visa information;
- Guest stay information, including, dates of arrival and departure, goods and services utilised, special requests made, observations about your service preferences (including room and vacation preferences), telephone numbers dialled and faxes, texts and telephone messages received by us;
- Your credit card details, and your account details and credentials for any frequent guest, flyer or travel partner programme;
- Any information necessary to fulfil special requests (e.g. health conditions that require specific accommodation or services);
- Information, feedback or content you provide regarding your marketing preferences, in surveys, sweepstakes, contests, or promotional offers, or to our websites or apps and those of third parties;
- Information collected whilst at Luxury Hotels Group Hotel through the use of closed circuit television systems, internet systems (including wireless networks that collect data about your computer, smart or mobile device, or your location), card key and other security and technology systems;
- Information collected whilst you access a Luxury Hotels Group app or Luxury Hotels Group website (we describe this in more detail in Sections 7 and 8 below);
- Contact and other relevant details concerning the employees of corporate accounts and vendors and other individuals with whom we do business (e.g. travel agents or meeting and event planners); and
- In limited cases, information relating to the credit of customers.
There may be instances in which the personal information that you provide to us or that we collect is considered Sensitive Personal Information under English privacy. Those laws define “Sensitive Personal Information” to mean personal information from which we can determine or infer an individual’s racial or ethnic origin, political opinions, religious beliefs or other beliefs of a similar nature, membership in a trade union or professional association, physical or mental health or condition, medical treatment, genetic data, sexual life or judicial data (including information concerning the commission or alleged commission of a criminal offence). In some very rare instances, financial records may form part of Sensitive Personal Information where you are located. We only process Sensitive Personal Information if and to the extent permitted or required by applicable law. When you agree to this Policy you are, to the extent required under English law, granting your express and written consent to the processing of any personal information that you provide to Luxury Hotels Group that is considered to be sensitive personal Information or financial information. Save to the extent required by law, you are not obliged to provide Luxury Hotels Group with any of your sensitive personal Information, and should you choose not to, this will not prevent you from purchasing any products or services from Luxury Hotels Group.
4. How We Use Personal Information
Subject to applicable laws, we may collect, use and disclose relevant portions of your personal information in order to:
- Provide and charge for hotel accommodation and other goods and services;
- Provide you with a better or more personalised level of service, including information and services from a third party (such as additional guest services at Luxury Hotels Group, local attractions and transportation options);
- Respond to requests for information and services, including services from a third party (such as restaurants or transportation providers);
- Fulfil contractual obligations to you, anyone involved in the process of making your travel arrangements (e.g. travel agents, group travel organisers or your employer) and vendors (e.g. credit card companies, airline operators and third party loyalty programmes);
- Conduct market research, customer satisfaction and quality assurance surveys, and direct marketing and sales promotions;
- Provide for the safety and security of staff, guests and other visitors;
- Administer general record keeping;
- Meet legal and regulatory requirements;
- Test and evaluate new products and services; and
- Process credit applications (for example in the context of Luxury Hotels Group).
Luxury Hotels Group uses and retains your personal information for as long as is necessary to fulfill the Purpose.
5. Disclosures of your Personal Information
From time to time, we may disclose your personal information. We would always make that disclosure in accordance with applicable law. In some jurisdictions, data privacy laws may require us to obtain your consent before we transfer your information from your originating country to other countries. When you agree to this Policy, you are, to the extent required and permitted under your local law, granting your consent to the transfer of your personal information to such other countries for the Purpose and to the extent stated in this section and as described in Section 4 above.
Circumstances where we might make such disclosure (in addition to those described in Section 4 above) include:
5.1 Our Agents, Service Providers and Suppliers
Like most hotels, we may outsource the processing of certain functions and/or information to third parties. We may also engage market research firms to assist us in contacting guests for the purpose of market research and quality assurance. When we do outsource the processing of your personal information to third parties or provide your personal information to third-party service providers, we oblige those third parties to protect your personal information in accordance with the terms and conditions of this Policy, with appropriate security measures.
5.2 Consumer Insights
Where we hold personal information about you, we may disclose this personal information to other companies that also hold information about you. These companies may combine the information in order to better understand your preferences and interests, thereby enabling them and us to serve you better. If your personal information is used for direct marketing purposes, you have the right to object to that by contacting us using the contact information provided under Section 12 below.
5.3 Credit Authorisation
When you request credit, your personal information will be used and disclosed to appropriate third parties in accordance with applicable laws for the purpose of determining whether to grant and maintain a line of credit to you.
5.4 Business Transfers
As we continue to develop our business, we may sell hotels and other assets, or cease being the manager or franchisor of a hotel that is currently part of our portfolio. In those circumstances, we may include the personal information collected about you, or control of that personal information, as a business asset in any such transfer. Also, in the unlikely event that we, or substantially all of our assets, are acquired, personal information collected about you, or control of such information, may be one of the transferred assets.
5.5 Legal Requirements
We reserve the right to disclose any personal information we have concerning you if we are compelled to do so by a court of law or lawfully requested to do so by a governmental entity or if we determine it is necessary or desirable to comply with the law or to protect or defend our rights or property in accordance with applicable laws. We also reserve the right to retain personal information collected and to process such personal information to comply with accounting and tax rules and regulations and any specific record retention laws.
6. Centralised Data Processing Activities
We have centralised certain aspects of our data processing activities in accordance with applicable laws. Whenever your personal information is transferred within Luxury Hotels Group, your personal information will be processed in accordance with the terms and conditions of this Policy and applicable laws.
7. Information We Collect When You Visit Us Online
If you access Luxury Hotels Group website, you may wish to know the following:
7.1 You Can Browse Without Revealing Who You Are
You can always visit our websites without logging in or otherwise revealing who you are.
7.2 Usage Information
When you visit our websites, we collect information about how you use those websites. Examples of such information include the Internet Protocol address automatically assigned to your computer each time you browse the Internet, the date and time of your visit, the pages you access and the amount of time you spend on each page, the type of Internet browser you use, your device’s operating system and the URL of any websites that you visited before and after visiting our website. That information is not linked to you as an individual unless you create a user profile, but we may keep records of the device being used.
7.3 Cookies and Other Similar Technology
If you do not want to accept cookies, you can block them by adjusting the settings on your Internet browser. However, if you block them, you will not be able to use all of the features of our website, including the customization features associated with creating a user profile.
Further information about cookies and other similar technology and how they work is available at allaboutcookies.org.
7.4 Social Media
Our website may also contain plug-ins and other features that integrate third party social media platforms into our website. You will be able to activate them manually. If you do so, the third parties who operate these platforms may be able to identify you, may be able to determine how you use this website and may link and store this information with your social media profile. Please consult the data protection policies of these social media platforms to understand what they will be doing with your personal data. If you activate these plug-ins and other features, you will be doing so at your own risk.
7.5 Creating a User Profile
You can create a user profile on Luxury Hotels Group website to, among other things, facilitate your online transactions, and to tailor your experience on our website to your interests. This allows us to make more appropriate recommendations to you. We may use the information you provide in your user profile to populate other databases maintained by us and our service providers, as applicable. By creating a user profile, you are agreeing that we may use the personal information you provide for these purposes.
You can view, update or remove any personal information that you have provided to us for inclusion in your user profile by amending your user profile online or emailing firstname.lastname@example.org. If you subsequently elect to remove your user profile, we reserve the right to use any personal information previously provided by you for inclusion in your user profile for record keeping and quality assurance purposes (unless we are required by law to delete or cease to process or use your personal information). Even if you choose not to create a user profile, you can still use our websites to search for and purchase services.
7.6 Links to Other Websites
If you visit Luxury Hotels Group website and decide, for example, to purchase a gift certificate, make a purchase or reservation of any kind, submit award request forms or apply for a job online, you may be seamlessly linked to websites maintained by third parties with whom we have contracted to provide those services. If you click on a link found on our website or on any other website, you should always look at the location bar within your browser to determine whether you have been linked to a different website. This Policy, and our responsibility, is limited to our own information collection practices. We are not responsible for, and cannot always ensure, the information collection practices or privacy policies of other websites maintained by third parties or our service providers where you submit your personal information directly to such websites. In addition, we cannot ensure the content of the websites maintained by these third parties or our service providers, even if accessible using a link from our websites. We urge you to read the privacy and security policies of any external websites before providing any personal information while accessing those websites.
Because the security of your personal information is important to us, we use Secured Socket Layer (“SSL”) software in order to encrypt the personal information that you provide to us. If your browser is SSL enabled (which most are), your transmission of personal information to us online will be encrypted. You can verify whether your personal information is transmitted using SSL encryption by confirming the symbol of a closed lock or solid key on the bottom bar of your browser window. You can also verify that your personal information will be encrypted using SSL encryption by making sure that the prefix for the web address listed for that page has changed from “http” to “https”. If you do not see the appropriate symbol and the “https” prefix, you should not assume that the personal information that you are being asked to provide will be encrypted prior to transmission.
The personal information we collect from you online is stored by us and/or our service providers on databases protected through a combination of physical and electronic access controls, firewall technology and other reasonable security measures. Nevertheless, such security measures cannot prevent all loss, misuse or alteration of personal information and we are not responsible for any damages or liabilities relating to any such incidents to the fullest extent permitted by law. Where required under law, we will notify you of any such loss, misuse or alteration of personal information that may affect you so that you can take the appropriate actions for the due protection of your rights.
7.8 Minor Children
Our websites do not sell products or services for purchase by children and we do not knowingly solicit or collect personal information from children. If you are under the age of 18 (or a minor in the jurisdiction in which you are accessing our websites), you may only use our websites with the involvement of a parent or guardian.
7.9 Targeted Advertising
Where permitted by law, we may work with other companies to show you advertisements we think you may find relevant and useful. This may include advertisements displayed on our own websites or apps, or advertisements from us displayed on other companies’ websites. The advertisements you see may be based on information collected by us or third parties and/or may be based on your activities on our websites or third-party websites.
If at anytime you download or register to use our apps, you may submit personal information to us such as your name, address, email address, phone number, date of birth, username, password and other registration information, financial and credit card information, personal description and/or image.
Further, when you use our apps, we may collect certain information automatically, including technical information related to your mobile device, your device’s unique identifier, your mobile network information, the type of mobile browser you use and information about the way you use the app.
Depending on the particular app you use and only after you have agreed to such collection, we may also collect information stored on your device, including contact information, friends lists, login information (where necessary to allow us to communicate with other apps at your request), photos, videos, location information or other digital content. Further details of the kinds of information we collect is set out in the privacy notice for each individual app.
You may always choose what personal information (if any) you wish to provide to us. However, if you choose not to provide certain details, some of your experiences with us may be affected (for example, we cannot take a reservation without a name and email address).
If you provide us with your contact details (e.g. postal address, email address, telephone number), we may contact you to let you know about the products, services, promotions and events offered in which we think you may be interested. We may also share your personal information with carefully selected third parties who may communicate directly with you. In some jurisdictions, data privacy laws may require us to obtain a separate consent before we do so. You can always choose whether or not to receive any or all of these communications by contacting us as described in Section 12 below or following the “unsubscribe” instructions contained in the communications.
If you have an account with Luxury Hotels Group we ask you to indicate your communication preferences at the time you apply for membership or when you create your user profile. We may also ask you to indicate how you would like to receive any offers, marketing and promotional information (e.g. via email or regular mail) and whether you would be willing to participate in surveys. Once you have indicated your preferences, you can always change them.
In some jurisdictions, in addition to you agreeing to this Policy, data privacy laws may require us to obtain a separate consent before we send you information that you have not specifically requested. In certain circumstances, your consent may be implied (e.g. where communications are required in order to fulfil your requests and/or where you have volunteered information for use by us). In other cases, we may seek your consent expressly in accordance with applicable laws (e.g. where the information collected is regarded to be Sensitive Personal Information under local regulations).
We will abide by any request from you not to send you direct marketing materials. When such a request is received, your contact details will be “suppressed” rather than deleted. This will ensure that your request is recorded and retained unless you provide a later consent that overrides it.
10. Updating or Accessing Your Personal Information
With some limited exceptions, you have rights to access and update personal information held about you. If you want to inquire about any personal information we may have about you, you can do so by sending us a written request by email to the addresses set out in Section 12 below. Please be sure to include your full name, address and telephone number and a copy of a document evidencing your identity (such as an ID card or passport) so we can ascertain your identity and whether we have any personal information regarding you, or in case we need to contact you to obtain any additional information we may require to make that determination.
We reserve the right to charge you a fee, if permitted under applicable law, which is usually around GBP £10 for processing any such request. Where you make more than one request in quick succession, we may respond to your subsequent request by referring to our earlier response and only identifying any items that have changed materially.
You may request that we correct, cancel, and/or stop processing or using personal information that we hold about you. If we agree that the personal information is incorrect, or that the processing should be stopped, we will delete or correct the personal information. If we do not agree that the personal information is incorrect we will tell you that we do not agree, explain our refusal to you and record the fact that you consider that personal information to be incorrect in the relevant file(s).
11. Changes to this Policy
Just as our business changes constantly, this Policy may also change. To assist you, this Policy has an effective date set out at the end of this document.
12. Request for Access to Personal Information/Questions or Complaints
If you have any questions about this Policy, about the processing of your data described, or any concerns or complaints with regard to the administration of the Policy, or if you would like to submit a request (in the manner described in Section 10 above) for access to or deletion of the personal information that we maintain about you, please contact us by phone or email.
While this Policy alone does not create contractual rights, Luxury Hotels Group has ensured compliance with its legal obligations in England in relation to personal information by creating a set of binding standards and policies. As a result, depending on your circumstances and location, you may be able to enforce your privacy rights using those standards or policies through that regulator or a court. If you would like to know more about these standards and policies, please contact Luxury Hotels Group.
All requests for access to your personal information must be submitted in writing by email from the email address we hold on file although we may in addition request proof of identification. We may respond to your request by letter, email, telephone or any other suitable method.
In the event of any inconsistencies between the English version of this Policy and any version of this Policy in any other language, the English version shall prevail.