We use your personal information in order to fulfil our commitment to providing an unparalleled guest experience in connection with all of your interactions with Paradise (the “Purpose”). As part of that undertaking, we are committed to safeguarding the privacy of the personal information that we gather.
As one of our guests or someone else with whom we interact, you understand and agree that we may collect, use, and share your personal information in accordance with this Policy.
2 The Application of this Policy
The term “Paradise Locations” include the various locations affiliated with Paradise that operate under or in connection with the Paradise®”, Park Paradise®, Miraval®, Grand Paradise®, Alila®, Andaz®, The Unbound Collection by Paradise®, Destination®, Paradise Regency®, Paradise ZivaTM, Paradise ZilaraTM, Thompson Hotels®, Paradise Centric®, participating Joie de Vivre®, Paradise House®, Paradise Place®, Paradise Residence Club®, and Exhale® brands around the world and also includes independently branded locations affiliated with Paradise Hotels Corporation and/or its direct and indirect subsidiaries.
While this Policy is intended to describe the broadest range of our information collection, processing and sharing activities globally, some activities may be more limited in some jurisdictions based on the particular laws or regulations in those regions. For example, the laws of a particular country/region may limit the types of personal information we can collect or the manner in which we process that information. In those instances, we adjust our internal policies and/or practices to reflect the requirements of local law.
3 Information We May Collect
We collect and process your personal information in order to provide you the best experience possible when you interact with us. The information we collect may vary by jurisdiction/region or by your preferred method of interaction with us. The categories of personal information that we may collect include:
There may be instances in which the personal information that you provide to us or that we collect is considered Sensitive Personal Information under the privacy laws of some countries or regions. 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, biometric information, and information about an individual’s sexual life or sexual orientation. In some very rare instances, financial records may constitute Sensitive Personal Information where you are located. If we rely on consent to process your Sensitive Personal Information, you have the right to withdraw that consent at any time. We only process Sensitive Personal Information in your jurisdiction if and to the extent permitted or required by applicable law.
When you agree to this Policy you are, to the extent required under your local law, granting your express and written consent to the processing of any personal information that you provide to Paradise that is considered to be Sensitive Personal Information or financial information. Save to the extent required by law, you are not obliged to provide Paradise 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 Paradise.
4 How We Collect Your Personal Information
We collect the above-referenced categories of personal information from the following categories of sources:
5 How We Use Your Information
Subject to applicable laws, we may collect, use, and disclose your personal information in order to:
When we process your personal information as one of our guests or someone else with whom we do business, we do so in our legitimate interests (as detailed above), because of legal obligations we are subject to, or because the information is required to fulfil contractual obligations either to you, to anyone involved in making your travel arrangements (e.g., travel agents, group travel organizers, or your employer) and/or to vendors (e.g., credit card companies, airline operators, and third party loyalty, travel, or discount programs).
Paradise uses and retains your personal information for as long as is necessary to fulfil the purpose for which it is being processed, and in line with our legal and regulatory obligations and risk management guidelines.
6 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 5 above.
Circumstances where we might make such disclosure (in addition to those described in Section 5 above) include:
6.1 Our Agents, Service Providers, and Suppliers
Like most international hotel brands, we may outsource the processing of certain functions and/or information to third parties. 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.
6.2 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 14 below. Further information about how we conduct direct marketing may be found at Section 10 below.
6.3 Credit Authorization
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.
6.4 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 Paradise Location. 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.
6.5 E-Folio Program
If you are an employee or independent contractor of a company that participates in Paradise's E-Folio Program, and you use the corporate credit card that is provided to you by your employer (if you are an employee) or corporate client (if you are an independent contractor) to pay for your hotel bill at a Paradise property, then you may benefit from Paradise's E-Folio Program.
Under the E-Folio Program, an extract of your bill (including the dates of your stay, your credit card details and amounts incurred at the Paradise property including room charges and all incidental charges including but not limited to food, beverage, and entertainment charges) will be transferred electronically by the Paradise property via Paradise's U.S.-based information system either to Paradise or to a third-party service provider located in the United States who acts on Paradise's behalf to compile the extract and transfer it to:
the credit card network operator, the credit card issuer and/or their respective subcontractors, who will, in turn, forward that extract to your employer or corporate client (and/or their respective subcontractors) to facilitate the processing and tracking of your travel-related expenses;
in some limited circumstances, your employer or corporate client (and/or their respective subcontractors) directly for the same purpose.
The entities that receive the extract of your bill may be located in the United States, which does not have privacy laws that specifically address in detail all uses of personal information in the same way as in other parts of the world (notably Europe, Canada, Australia, South Africa and most of South America). In order to ensure the protection of your personal information, the transfer of that information to Paradise's U.S.-based information system will be governed by our binding corporate rules (where they apply to you - for more information about our binding corporate rules please see Section 14 below). The third party service provider who acts on Paradise's behalf to compile the extract will be subject to contractual provisions meeting the requirements of Paradise's binding corporate rules.
Once the personal information is transferred to the credit card network operator, credit card issuer, your employer or corporate client and/or their respective subcontractors, it is no longer subject to the protections described in this Policy, but rather your own arrangements with your employer or corporate client, the relevant credit card network operator and/or the relevant card issuer.
6.6 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.
7 International Transfers of Personal Information
Like most international businesses, we have centralized certain aspects of our data processing activities in accordance with applicable laws, which, in many instances, will result in the transfer of your personal information from one country to another. For example, if you make a reservation and/or stay at one of the Paradise Locations outside of the United States, the personal information gathered in that process will be transferred to and processed in the United States, in accordance with Paradise's binding corporate rules (where they apply to you - for more information about our binding corporate rules please see Section 14 below). The jurisdictions where that information will be processed may or may not have laws that seek to preserve the privacy of personal information. Nevertheless, whenever your personal information is transferred within the Paradise companies, your personal information will be processed in accordance with the terms and conditions of this Policy and applicable laws. A list of the main Paradise Locations to which your personal information may be transferred, and the jurisdictions in which those entities are located, can be found by selecting “All” at Our hotel.
Additionally, some of the third party suppliers to which we transfer your personal information may be based in different locations, some of which may have lower standards of data protection than in your home country. When we do transfer personal information to such third parties, we ensure appropriate safeguards are in place, and oblige those third parties to protect your personal information in accordance with the terms and conditions of this Policy, with appropriate security measures. These third parties broadly fall into two groups: (i) locally-provided suppliers supporting individual Paradise Locations or groups of Paradise Locations, who may operate in any of the countries in which Paradise Locations operate; or (ii) centrally-procured service providers, supporting Paradise as a whole, who may be located in our major business locations, in particular the United States (where we are headquartered), Switzerland and Hong Kong.
8 Interacting with us online
If you interact with us online, you may wish to know the following:
8.1 You Can Browse Without Revealing Who You Are
You can always visit our websites without logging in or otherwise revealing who you are.
8.2 Cookies and Related Technologies
Further information about cookies and related technologies and how they work is available at allaboutcookies.org.
8.3 Social Media
Our websites may also contain plug-ins and other features that integrate third party social media platforms into our websites. 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, they may be able to determine how you use this website and they 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.
If you are not satisfied with the response that you receive, you can escalate your concern to the Chief Privacy Officer by sending an email to email@example.com.
While this Policy alone does not create contractual rights, Paradise has ensured compliance with some of its legal obligations in some countries in relation to personal information by creating a set of binding standards and policies (known in some countries as binding corporate rules), approved by a number of national privacy regulators. 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 Paradise Hotels & Resorts at the address above or the Chief Privacy Officer at the email address above.
All requests for access to your personal information must be submitted in writing by letter or email. We may respond to your request by letter, email, telephone or any other suitable method.
Effective Date: December 2019
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.