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Privacy PolicyUser Privacy And Data Protection

Privacy Policy for Guests

1 Introduction
This privacy policy (the “Policy”) lets you know how Paradise Hotel, its direct and indirect subsidiaries, its affiliates, and the separate and distinct legal entities that manage, operate, franchise, license, own and/or provide services to the various locations operating under or in connection with a Paradise brand (collectively, “Paradise”, “us’, or “we”) collect, use, and share your personal information. This Policy gives effect to our commitment to protect your personal information and has been adopted by all of the, affiliates, subsidiaries, and all of the separate and distinct legal entities that make up Paradise, as defined in this Policy.

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
This Policy applies when you interact with Paradise either through our websites - including Paradise.com and our various booking sites - (collectively, “Website”), our mobile applications - including World of Paradise - (collectively the, “Application”), in person, such as when you visit us at Paradise Locations (as defined below), or when you communicate with us by phone, text, direct message, social media, or other similar functionality. This Policy also applies to the personal information about you that we receive from a third party, unless specifically covered by such third party’s privacy policy or Paradise’s Privacy Policy for Employees.

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.

If you are a Paradise colleague, please see the applicable Paradise Privacy Policy for Employees or your applicable employer’s privacy policy, as this Policy does not apply to your information, unless collected in your capacity as a guest.

This Policy applies unless there is a specific country/region privacy policy for you based on your citizenship/residency or if the Paradise Location is in such country/region or if the Paradise Privacy Policy for Employees applies.

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:

  • Contact and Identification Information: We may collect information such as your name, contact details (e.g. phone numbers, address, or email) professional title, employer or professional affiliations, and passport and visa information;
  • Account Information and Marketing Preferences: We may collect your account details and credentials for the Paradise frequent guest program and any frequent flyer or travel partner program. We may also collect information on your marketing preferences;
  • Stay and Purchase Information: We may collect information such as the hotels where you have stayed or booked a stay, dates of arrival and departure, goods and services purchased or utilized at Paradise Locations or on the Website or Application, physical and digital room key usage, special requests made, service and stay preferences (including room and vacation preferences), telephone numbers dialed and faxes sent, calls or messages received, and any feedback or content you provide to us regarding your stay. We may also collect information through the use of closed circuit television systems, internet systems (including wired or wireless networks, smart or mobile device, or your location), and other security and technology systems;
  • Internet & Network Activity: We may collect the Internet Protocol (“IP”) address automatically assigned to your computer or device each time you interact with us online. We also use cookies and related technologies to collect information related to how you interact with our Websites, Applications, and online content. We may collect 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, your search terms on the Website, the URL of any websites that you visited before and after visiting our Websites (including the advertisement that referred you to our Website), and whether you click or interact with our digital content and advertising on other sites. When you access the Application or the mobile version of the Website, we collect your device, your device’s unique identifier, your mobile network information, and the type of browser you use. For information about how Paradise uses cookies and related technologies and how to disable such cookies and related technologies, Please see Section 8.2 below;
  • Payment and Credit Information: We may collect credit card and other payment method details. In limited cases, we may also collect information relating to the credit of customers;
  • Location Information: We may automatically collect information about your precise geolocation when you access the Website or Application to the extent permitted by applicable law. We may also collect information about your general location using your IP address and your zip code;
  • Demographic Information: We may collect demographic information, such as your gender, nationality, age, and date and place of birth;
  • Biometric and Health-related Information: We may collect health-related information you provide us to fulfil special requests (e.g., health conditions that require specific accommodation or services), or biometric information, such as information used for facial recognition;
  • Audio and Visual Information: We may record our customer service calls and security footage of our properties, which may include your voice and/or image;
  • Preferences and Inferences: We may collect your preferences or make inferences about you, reflecting what we believe to be your preferences, characteristics, and predispositions, based on other personal information we have
  • Device Content: With your permission, we may collect information relating to the content on your device. For more information, see Section 9.

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:

  • Directly from you: Much of the personal information we process is information that you or someone acting on your behalf directly provides to us. For example, you may provide us with Contact and Identification Information, Stay and Purchase Information, Payment Information, Demographic Information, and Health-related Information, when you create an account; book a reservation; complete surveys, sweepstakes, contests or promotional offers; contact customer service; or contact us via email, text, or chat, over the phone, in person, or through third parties.
  • From your devices and our networks: We use cookies and related technologies to automatically collect personal information from and across your devices when you interact with the Website, Application, our emails, or other online content.
  • From other businesses or individuals: We work with business and marketing partners and social media platforms that give us personal information about you that they have collected either directly or indirectly from you. We also use features that let your friends and family give us your personal information, for example when a family member or friend checks in on your behalf. We also may receive your personal information from (i) someone acting on your behalf, such as your travel agent or your employer (where your employer books travel for you), (ii) your travel provider, such as an airline, or (iii) your third party card or loyalty scheme provider.
  • From social media: If you post to one of our pages on a social media site, we may receive Contact and Identification Information, Stay and Purchase Information, Internet and Network Activity, and any other personal information contained in your social media posts or profile.

5 How We Use Your Information
Subject to applicable laws, we may collect, use, and disclose your personal information in order to:

  • provide, charge for, and manage hotel accommodation and other goods and services;
  • provide you with customer support and a better or more personalized level of service at Paradise Locations as well as through the Website, Application, frequent guest program (e.g., World of Paradise®), third party applications, products or services, or through products or services Paradise develops in the future;
  • allow us to evaluate, analyze, and improve the functionality of our Websites, Applications, or goods and services;
  • facilitate concierge services on your behalf, e.g., restaurant, attraction and transportation transactions;
  • administer loyalty, travel, or discount programs and the Paradise frequent guest program (e.g., World of Paradise®);
  • administer contests, sweepstakes, or other promotions;
  • fulfil contractual obligations to you, anyone involved in the process of making your travel arrangements (e.g., travel agents, group travel organizers, or your employer) and vendors (e.g., credit card companies, airline operators, and third party loyalty, travel, or discount programs);
  • conduct market research, customer satisfaction and quality assurance surveys;
  • conduct marketing and sales promotions and serve targeted advertising for products, services, events, or promotions you might be interested in. Where permitted by law, we may work with other companies to serve advertisements or marketing that we think you may find relevant and useful. This may include advertisements displayed on our own Websites or Applications, contained in emails or other communications sent by us, 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, Applications or third-party websites;
  • provide for the safety and security of staff, guests and other visitors;
  • prevent, detect, and investigate fraud, cyber incidents, or other illegal activity;
  • communicate with you about our relationship, such as updates to this Policy or other important legal or business changes;
  • administer general record keeping;
  • meet legal and regulatory requirements;
  • test and evaluate new products and services;
  • process credit applications;
  • fulfil other purposes as disclosed to you in accordance with applicable law or with your consent; and
  • use certain pieces of personal information to verify your identity if you make requests regarding your personal information pursuant to this Policy. The verification steps and the pieces of personal information that we request may vary depending on the sensitivity and nature of your request.

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;
or

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
We and other parties use cookies and related technologies on our websites to allow us to evaluate and improve the functionality of our websites. These cookies and related technologies also allow us, advertising networks, social media companies, and other providers, to place advertisements and customized content.

Some of our websites allow you to manage your cookie preferences by clicking on the Cookie Center link that may be in the footer of those websites. Additionally, you can opt-out of certain uses of cookies for advertising purposes by visiting www.aboutads.info/choices and you can consult the user instructions for your Internet browser for additional controls relating to the use of cookies, including blocking certain cookies by adjusting the settings on your Internet browser. Choices you make regarding cookies are website, device, and browser specific, and are deleted whenever you clear your browser’s cache. If you block cookies, you will not be able to use all of the features of our websites, including the customization features associated with creating a user profile.

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 contact@hotelparadise.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.