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Last Updated: 9 December 2019
Effective Date: 1 January 2020
- 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. Do We Sell your Personal Data?
5. When and to Whom Do We Disclose Your Personal Data?
6. What Cookies and Other Technologies Do We Collect?
7. How Do We Protect Your Personal Data?
8. Third-Party Websites and Services
9. Cross-Border Data Transfers
10. How Long Do We Retain Your Personal Data?
11. How Can You Manage Your Preferences and Information?
12. What Are Your Rights and How To Exercise Your Rights?
13. What Information is Collected From Children?
15. How to Contact Us?
1. WHAT INFORMATION DOES ROSEWOOD COLLECT?
1.1 Personal Data from or about You
- Contact Details: Your name, e-mail address, phone number, physical address (billing and shipping), company affiliation, title;
- Demographic Data: Demographic information and location data, and government-issued identifiers (e.g., drivers’ license (including dates of birth), passport numbers or other national identifiers);
- Financial Details: Your credit card and/or debit card details;
- Guest Stay Information: 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;
- Log Details: IP addresses, online user account details or profiles when you log-in to your Rosewood account;
- Frequent Flyer Details: Frequent flyer and travel partner program affiliations and member number; hotel, airline and rental car packages booked;
- Social Media Details: Social media account information, profile pictures or posts;
- Your Feedback: 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;
- CCTV/Surveillance: For your safety and security, 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;
- Call Recordings: 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;
- Corporate Account Data: 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 Data: 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.
2. WHEN IS YOUR PERSONAL DATA COLLECTED?
We collect Personal Data about you in a number of ways, including when you provide such data to us. This includes:
We collect Personal Data, including from other sources. This includes:
- From Other Rosewood Hotel and Properties. The Personal Data you provide to us in connection with making a reservation, including your Contact Details, Demographic Data, Financial and Guest Stay Information, is shared and received with and from other Rosewood hotels and properties you have previously visited for purposes of meeting your reservation requests and preferences in advance.
- From Affiliates. We are a global enterprise and may receive your Personal Data from 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 with your Contact Details to provide you marketing communications, consistent with your choices. For a complete listing of our affiliates, please contact us as indicated in Section 15 or see www.rosewoodhotelgroup.com.
- From Other Sources. We may receive your Personal Data from other sources, like public databases, joint marketing partners, social media sites that consisting with your settings on related services,and other third parties including online booking services, travel agencies, airline, credit card partners and other parties who sell products and services under our brand. Such information usually includes your Contact Details, Social Media Details, Your Feedback and Other Data that you voluntarily choose to provide to us.
3. WHY IS PERSONAL DATA USED?
We use your Personal Data, both for business and commercial purposes 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. DO WE SELL YOUR PERSONAL DATA?
5. WHEN AND TO WHOM DO WE DISCLOSE YOUR PERSONAL DATA?
In the preceding twelve (12) months, we have disclosed or shared your Personal Data described as follows:
5.1 To Owners, Hotels and Other Properties. The Personal Data you provide to us in connection with making a reservation, including your Contact Details, Demographic Data, Financial Details, and Guest Stay Information, is shared with the respective Owner and hotel or property for purposes of meeting your reservation request. 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.
5.3 Commercial Service Providers and Suppliers. We outsource certain functions and/or information to third parties that provide services to Rosewood 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 described above 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.
5.4 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.
5.7 Co-Sponsors of Promotions and Sweepstakes. Your Personal Data, including your Contact Details or Feedback, 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.
5.8 Social Media and Message Boards. If you connect to one of our social media pages, we may disclose your Personal Data including your Social Media Details 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.
5.9 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.
5.10 Anonymized Data. We may share aggregated data with third parties collectively in an anonymous way, which does not reveal Personal Data.
6. WHAT COOKIES AND OTHER TECHNOLOGIES DO WE COLLECT?
6.1 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.
6.3 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.
6.4 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.
6.6 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.
6.7 Do Not Track. Currently, we do not alter our data collection and use practices in response to Do Not Track signals.
7. 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.
8. THIRD-PARTY WEBSITES AND SERVICES
8.1 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.
9. CROSS-BORDER DATA TRANSFERS
9.1 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 5.
9.2 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 15 below.
10. HOW LONG DO WE RETAIN YOUR PERSONAL DATA?
11. HOW CAN YOU MANAGE YOUR PREFERENCES AND INFORMATION?
11.1 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.
11.2 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.
11.3 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.
11.4 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.
11.5 Mobile Apps. You can control whether our Apps send you push notifications by change your notification settings on your mobile device.
11.6 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.
12. WHAT ARE YOUR RIGHTS AND HOW TO EXERCISE YOUR RIGHTS?
Under applicable law and regulations, you may, at any time, exercise certain rights, as described below:
12.1 For Residents in the European Union/European Economic Area
- 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.We will usually share this information with you within one (1) month of you asking us for it.
- Rectify or Erase: The right to rectification or erasure of your Personal Data, which includes the right to have incomplete Personal Data completed.
- 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).
- 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.
- Data Portability: The right to data portability, which includes certain rights to have your Personal Data transmitted from us to you or another controller.
- 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 15.
- Complaint: If you think we have not complied with a data protection law, you may also have the right to lodge a complaint with a supervisory authority.
12.2 For California Residents
If you are a resident of California, California law provides you with specific rights regarding your Personal Data. These include:
- Information about Collection, Sale or Disclosure: The right to be informed of the categories of Personal Data that we collect about you, the categories of sources from which the Personal Data was collected, the business or commercial purposes for which the Personal Data is used, disclosed, or sold, and the categories of third parties with whom we share the Personal Data.
- Access to Specific Information: The right to request that we disclose certain information to you about our collection and use of your Personal Data over the past twelve (12) months. We will usually share this information with you within forty-five (45) days of you asking us for it.
- Deletion Request Rights: You have the right to request that we delete any of your Personal Data that we collected from you and retained, subject to certain exceptions.
- Personal Data Sales Opt-Out Rights: You have the right to opt-out of the sale of your Personal Data. However, as noted above, Rosewood does not engage in the sale of Personal Data.
- Non-Discrimination: Rosewood does not discriminate against you for exercising any of your privacy rights under CCPA or applicable law, including discrimination in the form of: denying you goods or services; charging you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; providing you a different level of quality of goods or services; or suggesting that you will receive a different price or rate for goods or services or a different level of quality of goods or services.
- 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.
12.3 For residents in other jurisdictions
Where permitted by applicable law, you may request access, correction and deletion of the Personal Data Rosewood has about you.
How to Exercise Your Rights
To exercise the rights described above, contact us as provided for in Section 15 below. Rosewood will respond to your request(s) as soon as reasonably practicable, but in any case, within the legally required period of time.
Your privacy and information security are important to us. For this reason, we verify your identity or authority to make the request and confirm the Personal Data relates to you, or others, if you are an authorized agent. Accordingly, Rosewood will collect your name, e-mail address and phone number to verify your identity. Upon receiving your request, we also contact you via email and/or other secured communication channel to verify your identity by asking you additional security questions in order to match to your identity with the data we maintain about you.
Please note that, if we cannot verify your identity, we are not obligated to provide you or your Authorized Agent information regarding your Personal Data.
For Your Security
Rosewood does not collect sensitive information, such as your full credit card details, social security or national identification number, to verify your identity. Please do not send Rosewood sensitive information and be aware of any phishing scams or fraudulent calls requesting such information from you.
While we maintain commercially reasonable safeguards to protect your Personal Data, no method of transmission is 100% secure and we do not guarantee or warrant that your Personal Data is under absolute security with the existing security technology.
Submitting Request via an Authorized Agent
You may also exercise your rights via an authorized agent (“Authorized Agent”).
An Authorized Agent can be a third party that you authorize to act on your behalf, such as a third party with power of attorney.
If you are a resident of California, an Authorized Agent can only be a person or a business entity that you authorize to act on your behalf to submit a verifiable consumer request related to your personal data.
When an Authorized Agent is submitting a request on your behalf, we will require such Authorized Agent to provide evidence of their entitlement, e.g., a written permission, declaration or affidavit demonstrating that they have authority to make the request on your behalf, and the Authorized Agent would have to verify their own identity directly with us.
Disclosure of Personal Data
Once we have verified you or your authorized agent’s identity, we will disclose the specific pieces of Personal Data we collected about you, which will be made in writing and delivered through your account with us, if you maintain such an account. If you do not maintain an account with Rosewood, we will provide such information by mail or electronically, at your option, in a readily useable format that allows you to more readily transmit the information from one entity to another entity.
13. WHAT INFORMATION IS COLLECTED FROM CHILDREN?
13.1 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.
13.2 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.
15. HOW TO CONTACT US
- Email us at email@example.com
- Calls us toll free in the U.S. at 1-866-923-1608
- Write to us at either
Rosewood Hotel Group
Rosewood Hotel Group
You may also submit a request to exercise your rights by visiting <<Privacy Rights Request>>, where you will find more information on how to submit a request and how do we handle your request.