Last Updated: 29 January 2021
Effective Date: 1 February 2021
Rosewood Hotel Group and its affiliates (collectively, “Rosewood”, “we”, “our” or “us”) are committed to safeguarding your privacy and want you to be familiar with how we collect, disclose and otherwise use information about you. References in this Privacy Policy to “Rosewood,” “we,” “our” or “us” are references to the entity responsible for the processing of your personal data, which generally is the entity that obtains your personal data in the respective case, or the data controller.
This Privacy Policy describes:
This Privacy Policy excludes those websites and online services that have separate privacy policies and do not incorporate this Privacy Policy by reference or otherwise. This Privacy Policy also does not apply to the collection and processing of personal data by the owners of hotels who are third parties not belonging to the Rosewood Hotel Group and its affiliates. For example, third-party owners of hotels may use e-mail or other methods of marketing communication to contact their guests and they are solely responsible for these communications. Please see the hotel owner’s own privacy notice to understand how it will treat your information. Different privacy policies also may apply to other parts of our web presence – for example, web pages for online recruitment.
In certain hotels, Rosewood will provide you with a Guest Privacy Notice (“Notice”) in addition to this Privacy Policy which sets out specifics of the data collection and processing for the hotel and forms together with this Privacy Policy the basis upon which your personal data will be processed by Rosewood.
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.
Please read this Privacy Policy carefully. By providing your personal data and other information through our Services, you acknowledge that your personal data will be processed pursuant to the terms of this Privacy Policy. If any term in this Privacy Policy is unacceptable to you, please do not use the Services or provide any personal data.
This Privacy Policy is written in English and may be translated into other languages. In the event of any inconsistency, the English version shall prevail.
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?
14. What About Privacy Policy Modifications?
15. How to Contact Us?
1. WHAT INFORMATION DOES ROSEWOOD COLLECT?
1.1 Personal Data from or about You
The term “Personal Data” as used in this Privacy Policy refers to any information relating to an identified or identifiable individual, or as defined under applicable law. When you contact us, book as a guest, visit one of our hotels or properties, or use our Site, we collect certain Personal Data from you. In the preceding twelve (12) months, we have collected categories of Personal Data such as:
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:
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.
3.2 Legitimate Business Reasons. We use your Personal Data where we have a legitimate business reason to do so, pursued by a third party or us. This includes providing you with superior customer service and a personalized experience when staying with us, keeping our Services safe and secure and to protect our operations or those of any of our affiliates or other third parties, and 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 Data we collect and how it is used. We encourage you to read these rules carefully. Such legitimate business reasons also include providing you with information that you have requested and responding to your inquiries, anonymizing Personal Data provided under this Privacy Policy to improve the Services and guiding the development of new features and services, detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity; debugging and repairing errors; verifying customer information; and subject to applicable law and regulations, in the event of a corporate event such as a sale, merger or change in control.
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?
Rosewood does not rent or share your information without your consent except in accordance with this Privacy Policy or for the purposes disclosed on any online form or location on the Services where you provide Personal Data to us. Rosewood also does not engage in the sale of 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.
You can object to the retention of your Personal Data for this purpose by contacting us as described in Section 15 of this Privacy Policy.
5.2 To Affiliates. We are a global enterprise and may disclose your Personal Data described in this Privacy Policy 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 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.
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.
5.5 Travel-Related Service Partners. We may share your Personal Data with select third parties, including your Contact Details, Demographic Data, Financial Details, Frequent Flyer Details, and Guest Stay Information. For example, we may help arrange rental cars and share Personal Data with them in order to provide those services. We also may work with third parties, such as travel agencies and airlines to help provide you with a single source for purchasing travel-related services. This Privacy Policy does not apply to information that you provide directly to third parties.
5.6 E-Folio Program. If you are an employee or corporate client of a company that participates in Rosewood’s E-Folio Program, a summary of the goods and services provided to you during your stay will be shared with the payment card provider, who in turn, may share that summary with your employer or corporate client. Once the Personal Data, including your Corporate Account Data, is transferred to the credit card issuer, credit card network operator, your employer and/or corporate client, it is no longer subject to the provisions of this Privacy Policy. Please visit the privacy policies of your employer or corporate client, the relevant payment card provider and card issuer for more information on their data privacy and protection practices.
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.
5.11 Legal Obligation. If we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, pursuant to a legal request, subpoena or other legal processes, or in order to enforce or apply our Terms of Use and other agreements, including for billing and collection purposes; or to protect the rights, property, or our safety, our guests, or others. This may include exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
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.
6.2 Cookies. As further described in our <<Cookie Policy>>, we use cookies and other similar technologies (e.g., web beacons, pixels, ad tags and device identifiers) to recognize you and/or your device(s) on or across different Services and devices. We also allow other third parties to use cookies as described in our <<Cookie Policy>> You can control cookies through your browser settings and other tools. For more information on the cookies we collect and how to disable them, please visit our <<Cookie Policy>>.
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.
6.5 If you do not want incorporated social networks to gather data about you via our Site, you must log out on the respective domain of the social network before visiting our Site. If you wish to prevent information being exchanged with the above-mentioned social networks during your visit to our Site, you can opt out of cookies through your browser settings and other tools. For more information, please visit our <<Cookie Policy>>.
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.
8.2 This Privacy Policy only addresses the collection, use, and disclosure of information by us through your interaction with our Services. This Privacy Policy does not address the policies or practices of any third parties or any third-party websites or features that are linked to or available from our Services. If you provide any information to any other third parties, different rules regarding the collection and use of your Personal Data by such third parties may apply. Please contact these entities directly if you have any questions about their privacy practices.
8.3 We also may partner with a limited number of Internet providers to offer Internet access to our guests. Your use of on-property Internet service is subject to the third-party Internet provider’s terms of use and privacy policy, which you can access using the links on the service sign-in page, or by visiting the Internet provider’s website.
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?
We retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by applicable law. Note that we may need to retain certain information for recordkeeping purposes and/or to complete transactions (e.g., when you make a purchase or reservation), and you may not be able to change or delete the Personal Data you provided until after completion of such purchase or reservation.
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
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:
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.
Verification Process
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.
14. WHAT ABOUT PRIVACY POLICY MODIFICATIONS?
We reserve the right to change this Privacy Policy at any time. Any changes we make will be posted on this page. If we make material changes to how we treat your Personal Data, we will notify you through a notice on the Services home page. The date this Privacy Policy was last revised is identified at the top of the page. It is your responsibility to ensure that we have a deliverable e-mail address for you, and for you to periodically monitor and review any updates to this Privacy Policy. Your continued use of our Services after such amendments will be deemed your acknowledgement of these changes to this Privacy Policy.