Last Updated: 15 December 2022
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 and for What Purposes is Your Personal Information Collected?
3. Why is Personal Information Used?
4. When and to Whom Do We Disclose Your Personal Information?
5. What Cookies and Other Technologies Do We Collect?
6. How Do We Protect Your Personal Information?
7. Third-Party Websites and Services
8. Where is Your Personal Information Stored and Cross-Border Data Transfers
9. How Long Do We Retain Your Personal Information?
10. How Can You Manage Your Preferences and Information?
11. What Are Your Rights and How To Exercise Your Rights?
12. What Information is Collected From Minors under 16?
14. How to Contact Us?
1. WHAT INFORMATION DOES ROSEWOOD COLLECT?
1.1 Personal Information from or about You
1.2 Sensitive Personal Information
From time to time, you may provide or we may collect “Sensitive Personal Information” which refers to Personal Information that is likely to result in damage to the personal dignity of any natural person or damage to his or her personal or property safety once disclosed or illegally used, including such information as biometric identification, religious belief, specific identity, medical health, financial account and whereabouts and tracks, as well as the Personal Information of minors under the age of fourteen. 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 Information where there are specific purposes and sufficient necessity. Unless otherwise required by applicable law, you are not required to provide us with any of your Sensitive Personal Information. Should you choose not to, your decision would not prevent you from using our Services.
2. WHEN AND FOR WHAT PURPOSES IS YOUR PERSONAL INFORMATION COLLECTED?
We collect Personal Information about you in the manners and for the purposes as listed below:
We collect Personal Information, including from other sources. This includes:
3. WHY IS PERSONAL INFORMATION USED?
We use your Personal Information, both for business and commercial purposes as set forth below.
3.1 Performance of a Contract. We process your Personal Information 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.
3.2 To Comply with Legal Obligations. We process your Personal Information where it is necessary to comply with legal obligations to which it may be bound. This includes keeping our Services safe and secure, detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, debugging and repairing errors, verifying customer information 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.
3.3 With Your Consent. We process your Personal Information when we have your valid consent to do you, including to providing you with superior customer service and a personalized experience when staying with us, protecting our operations or those of any of our affiliates or other third parties, distributing and responding to surveys regarding your experience, allowing you to participate in sweepstakes, contests, and other promotions and to administer these activities (please bear in mind that some of these promotions have additional rules, which could contain additional information regarding what Personal Information we collect and how it is used, and we encourage you to read these rules carefully), 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, providing you with information that you have requested and responding to your inquiries, and to process Sensitive Personal Information you may have provided us in connection with your stay; for example, any dietary restrictions or special accommodations for physical and medical conditions. Such circumstances also include, subject to applicable law and regulations, processing your Personal Information in the event of a corporate event such as a sale, merger or change in control.
3.4 In An Emergency. In certain circumstances when it is not possible to obtain your consent, it may be necessary for us to process your Personal Information, including Sensitive Personal Information you provided through our Services, where it is necessary to respond to public health emergencies or to protect the life, health and property safety of natural persons in emergency situations, for example in the event of a medical emergency.
4. WHEN AND TO WHOM DO WE DISCLOSE YOUR PERSONAL INFORMATION?
4.2 Sharing of Personal Information. We may disclose or share your Personal Information described as follows:
To Owners, Hotels and Other Properties. The Personal Information 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 Information, 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.
Prior to sharing, we will separately inform you of the names of the receiving parties, their contact information, the purpose and manner of processing and the types of Personal Information, and obtain your consent when required and in accordance with the applicable laws and regulations.
In addition, we may share aggregated data with third parties collectively in an anonymous way, which does not reveal Personal Information.
4.3 Disclosure of Personal Information. In general, we do not disclose your Personal Information. Having said that, if you connect to one of our social media pages, we may disclose your Personal Information including your Social Media Details to your friends associated with your social media 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 Information in this context. We are not responsible for the privacy practices of other users including web operators to whom you provide your Personal Information.
4.4 Third-party SDK. To provide and optimize our services, third-party SDKs are embedded in our applications. The following lists the names of the third-party SDKs we currently embed, the types of Personal Information collected, and the purpose of collection and use. If you have questions about the collection of your Personal Information by the third parties through the SDKs, please refer to the privacy policies of such third parties.
|Name of the SDK
||Provider of the SDK
||Purposes of the SDK
||Application where the SDK is embedded
||Types of Personal Information collected by the SDK
||AutoNavi Holding Ltd.
||Precise Location, POI Search, Distance Calculation, Point Selection on Map
||Shipping address and location input by User/Merchant
||When user place order, add address||https://lbs.amap.com/dev/index|
|Tencent Technology (Shenzhen) Co., Ltd.
||Precise Location, POI Search, Distance Calculation, Point Selection on Map
||Shipping address and location input by User/Merchant||When user place order, add address||https://www.tencent.com/zh-cn/privacy-policy.html|
||Beijing Baidu Netcom Science and Technology Co.,Ltd.
||Precise Location, POI Search, Distance Calculation, Point Selection on Map
||Shipping address and location input by User/Merchant||When user place order, add address
|Google LBS||Google Inc.||Precise Location, POI Search, Distance Calculation, Point Selection on Map||Store address selected by Merchant||User Authorization||https://developers.google.com/maps/documentation/geocoding/start|
|Express 100 Express in-transit monitoring||Shenzhen Qianhai Baidi Network Co.,Ltd.||Express Information Query, Express Real-time Tracking, Express Company Query||User's mobile phone number, courier tracking number||When user place order, add address||https://www.kuaidi100.com/about/private.shtml|
|Kuaidiniao express in-transit monitoring||Shenzhen Kuaijin Data Technology Service Co., Ltd||Express Information Query, Express Real-time Tracking, Express Company Query||User's mobile phone number, courier tracking number||
When user place order, add address
|WeChat Logistics Assistant||Tencent Technology (Shenzhen) Co., Ltd.||Express Information Query, Express Real-time Tracking, Express Company Query||User's mobile phone number, courier tracking number||When user place order, add address||http://weixin.qq.com/cgi-bin/readtemplate?lang=zh_CN&t=weixin_agreement&s=privacy|
|Linqu Paotui &Delivery||Shanghai Linqu Network Technology Co.,Ltd.||Intra-city Logistics Distribution, Logistics Order Information Query, Courier Tracking||User's mobile phone number, delivery address, product information, latitude and longitude information, order information
||When user place order||http://tg.linjia.me/|
|Dada Express||Dada Nexus Limited||Intra-city Logistics Distribution, Logistics Order Information Query, Courier Tracking||User's mobile phone number, delivery address, product information, latitude and longitude information, order information||
When user place order
|SF Intra-city Delivery||
Shenzhen Shunfeng Tongcheng Logistics Co., Ltd.
|Intra-city Logistics Distribution, Logistics Order Information Query, Courier Tracking||User's mobile phone number, delivery address, product information, latitude and longitude information, order information
||When user place order||https://www.sf-cityrush.com/armor/agreement/3c2fe074-f811-4503-a33c-ce4b88a6ef80.html|
|Shansong Intra-City Delivery||Beijing Tongcheng Bing Technology Co., Ltd.||Intra-city Logistics Distribution, Logistics Order Information Query, Courier Tracking||User's mobile phone number, delivery address, product information, latitude and longitude information, order information||When user place order||http://m.ishansong.com/v2/activity/miniprogram-privacy.html|
|Meituan Intra-city Delivery||Beijing Sankuai Online Technology Co., Ltd.||Intra-city Logistics Distribution, Logistics Order Information Query, Courier Tracking||User's mobile phone number, delivery address, product information, latitude and longitude information, order information
||When user place order||https://peisong.meituan.com/app/zbRuleDetail?protocolType=3|
|Fengniao Intra-city Delivery||Alibaba Local Life Service||Intra-city Logistics Distribution, Logistics Order Information Query, Courier Tracking||User's mobile phone number, delivery address, product information, latitude and longitude information, order information||When user place order||https://terms.alicdn.com/legal-agreement/terms/suit_bu1_other/suit_bu1_other201906061426_71208.html|
Cathay Pacific Insurance Freight Insurance Service
|Cathay Century Insurance Co., Ltd.||Freight insurance, Insurance Claims Service||User's mobile phone number, delivery address, product information, latitude and longitude information, Order information, Logistics information, ID Card information, payment information||When user place order, apply for after-sales service||https://www.cathay-ins.com.cn/|
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.
6. HOW DO WE PROTECT PERSONAL INFORMATION?
We maintain commercially reasonable security safeguards that are designed to protect the Personal Information 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 Information 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. WHERE IS YOUR PERSONAL INFORMATION STORED AND CROSS-BORDER DATA TRANSFERS
We store your Personal Information within Mainland China. As an international hotel brand, Rosewood may also transfer and store your Personal Information to countries or regions outside Mainland China, and your Personal Information also may be processed by staff operating outside the Mainland China who work for us or other entities acting as parties entrusted by us to 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.
If we need to transfer your Personal Information outside Mainland China, we will fulfil the procedures specified in the relevant laws and regulations and protect your Personal Information with standards no lower than those required by the applicable laws and regulations in Mainland China.
9. HOW LONG DO WE RETAIN YOUR PERSONAL INFORMATION?
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 Information 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 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.
10.4 Mobile Apps. You can control whether our Apps send you push notifications by change your notification settings on your mobile device.
10.5 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 AND HOW TO EXERCISE YOUR RIGHTS?
You are conferred by the applicable laws and regulations in Mainland China with the following rights:
We will respond to your requests of exercising your data subject rights in accordance with the applicable laws and regulations in Mainland China. To the extent as permitted by such laws and regulations, we may not be able to respond to your request of exercising your rights in the following circumstances:
If we terminate our services or operations, we will notify you at least thirty (30) days in advance and will delete or anonymize your Personal Information after termination of services or operations.
How to Exercise Your Rights
To exercise the rights described above, contact us as provided for in Section 14 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 Information 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 Information.
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 Information, no method of transmission is 100% secure and we do not guarantee or warrant that your Personal Information 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.
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 Information
Once we have verified you or your authorized agent’s identity, we will disclose the specific pieces of Personal Information 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.
12. WHAT INFORMATION IS COLLECTED FROM MINORS UNDER 16?
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 their 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 Information of any kind whatsoever.
12.2 Should we inadvertently acquire Personal Information 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 minor under 16 does provide us with Personal Information over Services, a parent or guardian of that minor may contact us and upon notification, we will delete from our records any information collected from minors under the age of 16.
14. CONTACT US
If you have any questions or comments about our privacy practices or this Notice, or to exercise your rights with respect to your Personal Data (as applicable), you may:
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.