Last Updated: 18 May 2018
Effective Date: 24 May 2018
(1) Detailed information regarding what personal data and other information we collect from you, how we collect it, and how it is used;
(2) Further descriptions of the parties with whom and for what purposes your data is shared.
- our privacy practices when we communicate with you by offline channels, such as when you provide your information to our call centers, or in person (“Offline Services”); and
- the basis on which we will process personal data we collect from you or that you provide to us, and your choices with respect to that data.
Our privacy practices may be more or less limited in certain countries in which we operate to reflect local practices and legal requirements. We will specifically inform you, if this is the case.
1. What Information Does Rosewood Collect?
2. When is Your Personal Data Collected?
3. Why is Personal Data Used?
4. When Do We Disclose Your Personal Data?
5. What Cookies and Other Technologies Does Rosewood Collect?
6. How Do We Protect Your Personal Data?
7. Third-Party Websites and Services
8. Cross-Border Data Transfers
9. How Long is Your Personal Data Retained?
10. How Can You Manage Your References and Information?
11. What Are Your Rights Regarding Your Personal Data?
12. What Information is Collected From Children?
13. What About Policy Modifications?
14. How to Contact Us?
1. WHAT INFORMATION DOES ROSEWOOD COLLECT?
1.1 Personal Data
- Your name, e-mail address, phone number, physical address (billing and shipping), company affiliation, title;
- Demographic information and location, and government-issued identifiers;
- Your credit card and/or debit card details;
- Guest stay information, special requests and preferences (including preferred room type or floor, spend, vacation preferences, amenities requested, language preferences, interests, hobbies, ages of children or companions and any other aspects of the Services used), telephone numbers dialed, faxes and telephone messages received;
- IP addresses, online user account details or profiles when you log-in to your Rosewood account;
- Frequent flyer and travel partner program affiliations and member number; hotel, airline and rental car packages booked;
- Social media account information, profile pictures or posts;
- Information, feedback or content you provide regarding your marketing preferences, in surveys, comment cards, sweepstakes, or promotional offers on our Services and those of third parties;
- Images and visual recordings through the use of closed circuit television systems collected while visiting a Rosewood hotel or property, where permitted by applicable law;
- Conversations, including records or monitoring of guest service calls for quality assurance and training purposes, and other communications such as in-app messages or SMS text messages, where permitted by applicable law or based upon consent;
- Contact details concerning the employees of corporate accounts and vendors and other individuals with whom we do business (e.g., travel agents, bookers, event planners); and
- Other types of information that you voluntarily choose to provide to us.
1.2 Sensitive Personal Data
From time to time, you may provide or we may collect what is considered sensitive personal information or “special categories of personal data” under applicable privacy laws (herein referred to as “Sensitive Personal Data”). For example, you may disclose your religious affiliation to us when you host or attend an event at one of our hotels or provide your health information or dietary restrictions so that we can accommodate you during your stay.
We only process Sensitive Personal Data if and to the extent permitted and required by applicable law or with your express consent. Unless otherwise required by applicable law, you are not required to provide us with any of your Sensitive Personal Data. Should you choose not to, your decision would not prevent you from using our Services.
1.3 Personal Data from Third Parties
We may collect Personal Data related to you from third parties such as from airlines, payment card providers, travel agencies and online booking services, other affiliates and Rosewood hotel and properties you have previously visited, public databases, joint marketing partners, third parties who sell products and services under our brands and your social medial sites consistent with your settings on such services.
2. WHEN IS YOUR PERSONAL DATA COLLECTED?
We collect Personal Data about you in a number of ways, including:
- When you make reservations, stay at a property or plan or attend an event. Visitors who elect to make reservations using our Services or Offline Services will be asked to supply specific Personal Data, including name, e-mail address and contact information, as well as information to secure the reservation, such as a credit card number. We collect your Personal Data to provide you with services, including when you purchase goods and services, inform us of any requests, or take advantage of services such as concierge services, health clubs and spa treatments, activities, equipment rentals, and child care services. If you plan or host an event with us, we collect meeting and event specifications, such as your name, contact details, date of event, occasion, number of guest rooms required, and length of stay. We also collect information about guests that are a part of your group or event.
- When you sign up for promotional offers and sweepstakes. We collect your e-mail address when you sign up for promotional offers, newsletters or sweepstakes.
- When you provide your comments and feedback or communicate with us. We may collect Personal Data that you voluntarily share with us in surveys, guest feedback or comment cards, as well as on third-party websites. We also collect your Personal Data when you communicate with us via text or e-mail or otherwise, like WeChat.
- When you purchase a gift card. If you decide to purchase a gift card through rosewoodgiftcard.com, we collect Personal Data including the recipient’s name, e-mail address, shipping information, and any other information you voluntarily provide.
- From social media. We collect information from social media activity such as when you ‘like’ the Website, share content or follow us on social media sites like Facebook, Twitter, Pinterest Instagram, or WeChat. If you choose to log-in, connect with or link to Services using your social media account certain Personal Data is shared with us consistent with your settings within the social media service, such as location, check-ins, activities, interests, photos, status updates, as well as Personal Data that may be a part of your profile or friend’s profile.
- From other sources. We may receive your Personal Data from other sources, like public databases, joint marketing partners, and other third parties including travel agencies, airline and credit card partners.
- When you inquire about development or Owner opportunities. We may collect your Personal Data including your e-mail address when you contact us to learn more about development or ownership opportunities with us.
3. WHY IS PERSONAL DATA USED?
We use your Personal Data in a number of ways as set forth below.
3.1 Performance of a Contract. We process your Personal Data in order to perform a contract with you, including to complete your reservation, provide you goods and services that you requested, or to inform Owners of your stay in order to render services to you while visiting a hotel or other property that we manage.
3.3 To Comply with Legal Obligations. We process your Personal Data where it is necessary to comply with legal obligations to which it may be bound. This includes complying with legal processes, responding to requests from public and government authorities around the world, and pursuing available remedies or limit damage we or other third parties may sustain.
3.4 With Your Consent. We process your Personal Data when we have your valid consent to do you, including to communicate (including by e-mail and SMS) with you during your stay, to send you promotional offers, newsletters, information on us, our Services, and other marketing communications in accordance with your preferences; and to process Sensitive Personal Data you may have provided us in connection with your stay; for example, any dietary restrictions or special accommodations for physical and medical conditions.
3.5 Vital Interest. In certain circumstances when it is not possible to obtain your consent, it may be necessary for us to process your Personal Data, including Sensitive Personal Data you provided through our Services, where it is in your vital interest or in the interest of others, for example in the event of a medical emergency.
4. WHEN DO WE DISCLOSE YOUR PERSONAL DATA?
We may disclose or share your Personal Data as follows:
4.1To Hotels and Other Properties. The Personal Data you provide to us in connection with making a reservation is shared with the respective hotel or property for purposes of meeting your reservation request. The hotel or other property may be managed by us but owned by an independent third-party Owner. After your stay, we retain your Personal Data, including the details of your stay and your preferences (e.g., room, type, interest, hobbies, amenities used) to provide you personalized service during your next stay, subject to your preferences.
4.2 To Affiliates. We are a global enterprise and may disclose your Personal Data to other companies or hotels within our group, including in our offices in Hong Kong, the European Economic Area (EEA) and the United States in order to help render services to you associated with your stay at our hotels or other properties and to provide you marketing communications, consistent with your choices. For a complete listing of our affiliates, please contact us as indicated in Section 14 or see www.rosewoodhotelgroup.com.
4.3 Commercial Service Providers and Suppliers. We may outsource the processing of certain functions and/or information to third parties that provide services such as Services hosting, data analysis, payment and credit card processing, order fulfilment, customer service, e-mail delivery, financial services companies, delivery services, advertising networks, and information technology. We may also share your Personal Data with third-party providers that provide services such as spa treatment, salons, and restaurants within our hotels or other properties, or event planners or organizers of any event you plan or host with us.
4.4 External Partners. We may share your Personal Data to other partners, consultants and advisors who render services to us, including financial institutions, external auditors, lawyers, and credit card issuers.
4.7 Co-Sponsors of Promotions and Sweepstakes. Your Personal Data may be shared with our affiliates or other unaffiliated business partners that serve as co-sponsors or third-party sponsors of promotions, sweepstakes, or other contests if you enter into one of these activities on our Services.
4.8 Social Media and Message Boards. If you connect to one of our social media pages, we may disclose your Personal Data to your friends associated with your social medial account, to other website users, and to your social media account provider, in connection with your social sharing activities. We may make reviews, message boards, blogs and other user-generated content available to users on our Services. Any information disclosed in these areas is public information and you should accordingly exercise caution when deciding to disclose your Personal Data in this context. We are not responsible for the privacy practices of other users including web operators to whom you provide information.
4.9 Business Transfers. From time to time, we may sell our business, hotels and other assets or may cease managing a hotel or property owned by an Owner. In those circumstances, we may include Personal Data collected about you, or control of that Personal Data, as a business asset in any such transfer. For example, if we cease to operate a hotel property we do not own, the Owner may continue to have and use your Personal Data for continued business purposes consistent with the hotel’s operations, including direct marketing. Additionally, we may disclose your Personal Data to a buyer or other successor in the event of a merger, sale or other transfer event, in which Personal Data held by us about our users is among the assets transferred.
4.10 Anonymized Data. We may share aggregated data with third parties collectively in an anonymous way, which does not reveal Personal Data.
5. WHAT COOKIES AND OTHER TECHNOLOGIES DO WE COLLECT?
5.1 Automatic Data Collection. We may use automatic data collection technologies to collect certain statistical (non-personal) information about your equipment, browsing actions, and patterns, including (a) details of your visits to our Services, including traffic data and location data, date and time of access, frequency and other communication data; (b) information about your computer and internet connection, including your IP address, operating system, host domain, and browser type; and (c) details of referring websites actions, and patterns.
5.3 Social Media Plug-ins. One of the features of our Site is that it uses what are called social plugins (“plugins”) from the social networks Twitter, Facebook, YouTube, Pinterest, and Instagram. These plugins are indicated by the respective logo of the social network. When you access our Site, your browser establishes a direct connection with the servers of these social networks. The content of the plugin is transferred by the social network directly to your browser, which then integrates it into the Site.
5.3.1 Integration of the plugin causes Facebook, for example, to receive the information that you have loaded the corresponding page of our Site. If you are logged in with Facebook, it will be able to assign your visit to your Facebook account. Please note that an exchange of this information already takes place when you visit our Site, regardless of whether you interact with the plugin or not. If you interact with the plugins, such as by pressing the “Like” button, the corresponding information is sent directly to Facebook by your browser and saved there. You can find information on the purpose and extent of data acquisition as well as how the data is processed further and used by the social networks, together with your rights and optional settings to protect your private sphere, in the data protection notes of the social networks.
5.4 Wi-Fi and Location-Based Services. In the course and for the purpose of providing Wi-Fi services at our hotels and other properties, we may collect device identifiers (such as your IP address, or other unique identifier). Based upon your consent, we also may collect information about the physical location on your device through use of the Wi-Fi services or other technologies to provide you with personalized location-based services, such as to customized offers and promotions or to find a hotel near you.
5.5 Do Not Track. Currently, we do not alter our data collection and use practices in response to Do Not Track signals.
6. HOW DO WE PROTECT PERSONAL DATA?
We maintain commercially reasonable security safeguards that are designed to protect the Personal Data we collect against unauthorized use, disclosure, alteration or destruction. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure and we cannot guarantee or warrant that your Personal Data is under absolute security with the existing security technology. Additionally, when requesting information or sending information or forms to us by e-mail, please be advised that e-mail communication to and from our Services are not secure unless clearly noted otherwise. This is a risk inherent in the use of e-mail.
7. THIRD-PARTY WEBSITES AND SERVICES:
7.1 Our Services may contain links to, or have features that are hosted by, other third-party websites or services that are not owned or controlled by us. For example, we give you the opportunity to connect, link, or share our Services (and the content you access) via certain social media websites.
8. CROSS-BORDER DATA TRANSFERS:
8.1 The Personal Data and other information that we collect from you will be transferred to, and stored at, a destination outside the EEA. It also may be processed by staff operating outside the EEA who work for us or other entities acting as data processors processing data on our behalf. This includes staff and providers engaged in, among other things, the fulfillment of your request or order and the provision of support services. More information on to whom your data is disclosed can be found in Section 4.
8.2 To comply with applicable data protection law, we have implemented international data transfer agreements on the basis of EU Standard Contractual Clauses in order to provide appropriate and suitable safeguards for Personal Data transferred to countries outside the EEA where an adequate level of protection is not already guaranteed. A redacted copy (removing commercial terms) can be obtained by contacting us at the contact details provided in Section 14 below.
9. HOW LONG DO WE RETAIN YOUR PERSONAL DATA?
10. HOW CAN YOU MANAGE YOUR PREFERENCES AND INFORMATION?
10.1 Commercial E-mails. You may opt-out of receiving commercial e-mails from us by following the instructions contained in any of the commercial e-mails. Unsubscribing from one type of communication may not unsubscribe you from another type. Please note that even if you unsubscribe from commercial e-mail messages, we may still e-mail you non-commercial (transactional) e-mails related to your account and your transactions via the Services.
10.2 Owners (following termination or expiration of our management agreements) and third-party providers may use your Personal Data for marketing purposes. If you wish to opt-out of receiving offers directly Owners and third-party providers, you can follow the instructions in the e-mails that they send you.
10.3 EU Users and Commercial E-mails. If you are a user based in the EU, we only send you commercial e-mails when we have obtained your explicit prior consent, except where we have obtained your e-mail address in the course of a sale or negotiations for a sale of a product or service and where the commercial e-mails are only marketing similar products or services.
10.4 Text Messages and SMS. To opt out of text messages, reply STOP to the message you received or contact the hotel or property front desk to inform them you no longer wish to receive text messages.
10.5 Mobile Apps. You can control whether our Apps send you push notifications by change your notification settings on your mobile device.
10.6 Access and Connections to Social Media. If you registered with the Services through your social media account, or connected, linked, or shared your use of our Services via your social media profile, you can manage the permissions granted to such third-party social media services by accessing your user settings under your account. You also can remove our access to your social media account or otherwise control what information these third-party social media services share with us at any time by accessing the privacy settings in your social media account.
11. WHAT ARE YOUR RIGHTS REGARDING YOUR DATA?
Under applicable law and regulations, you may, at any time, exercise certain rights, including the following:
11.1 Access. The right to request access to your Personal Data, which includes the right to obtain confirmation from us as to whether Personal Data concerning you is being processed, and where that is the case, access to the Personal Data and information related to how it is processed.
11.2 Rectify or Erase. The right to rectification or erasure of your Personal Data, which includes the right to have incomplete Personal Data completed.
11.3 Restrict. The right to obtain a restriction of processing concerning your Personal Data, which includes restricting us from continuing to process your Personal Data under certain circumstances (e.g., where you contest the accuracy of your Personal Data, for a period enabling us to verify the accuracy of the personal data).
11.4 Object. The right to object to the processing of your Personal Data under certain circumstances, including objecting to processing your Personal Data for direct marketing purposes, or objecting to processing your Personal Data when it is done based upon legitimate interests.
11.5 Data Portability. The right to data portability, which includes certain rights to have your Personal Data transmitted from us to you or another controller.
11.6 Consent. Where we process your Personal Data based on your consent, the right to withdraw consent at any time with effect for the future. Any requests related to the above rights may be made by contacting us as set forth in Section 14.
11.7 Complaint. In some jurisdictions, you may also have the right to lodge a complaint with a supervisory authority.
11.8 Privacy Rights for California Residents. Under California Civil Code section 1798.83, California residents who have an established business relationship with us are entitled to ask us for a notice describing the types of personal customer information we have shared with third parties for those parties’ direct marketing purposes during the preceding calendar year. That notice will identify the categories of information shared with third parties, the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. If you are a California resident and would like to request a copy of this notice, please submit a written request to Rosewood Hotel Group, 9220 W. Sunset Blvd, Ste. 300, West Hollywood California, 90069, Attn: Legal Department.
12. WHAT INFORMATION IS COLLECTED FROM CHILDREN?
12.1 We have not designed the Services for, and do not intend for them to be used by, anyone under age 16. We do present information regarding our Rose Buds® program on our Services for the reference of adults that are interested in activities at our locations for children. Accordingly, the Services should not be used by anyone under age 16 without adult supervision. If you are under 16, please do not provide Personal Data of any kind whatsoever.
12.2 Should we inadvertently acquire Personal Data or other information from users under the age of 16, we will not knowingly provide this data to any third party for any purpose. If a child does provide us with Personal Data over Services, a parent or guardian of that child may contact us and upon notification, we will delete from our records any information collected from children under the age of 16.
14. HOW TO CONTACT US:
Rosewood Hotel Group
36/F New World Tower 1
18 Queen's Road Central. Hong Kong
Attn: Legal Department