- we will not collect personally identifiable information like your name, email, mailing address or telephone number ("Personal Information") in a manner inconsistent with this policy;
- we will not disclose your Personal Information to third parties except as described in this policy, or unless you have authorized us to do so in advance;
- we will allow you to view, correct or remove your Personal Information and other information that is accessible to you as part of your account as a registered user of the site; and
- we will take reasonable steps to protect the security of the Personal Information we collect from you. The remainder of this policy describes our information handling practices in detail.
We collect, process and use your Personal Information for purposes of providing the services requested by you from us, and in particular to register and manage your account, process your reservations, requests, and payments, and to communicate with you in connection with the above-listed purposes. Refusal to provide Personal Information for the above-mentioned purposes may affect our ability to fulfill contractual obligations or to provide you with services, information, and or material requested by you. With your consent, we may also use your Personal Information in order to provide you with advertising and promotional materials relating to us or other third parties using automatic means (such as e-mail or fax.), as well as paper mail and operator-assisted phone calls. Certain Personal Information that you have provided us may be given to the airline, car rental agency, hotel or property, travel package vendor or other involved third parties to fulfill your travel arrangements.
If you decide to register with us or to make a reservation on this site, we will collect Personal Information about you, such as your name, email and mailing addresses, telephone number(s), credit card information, and passport number, that you voluntarily share with us. We process Personal Information mainly by electronic and automatic means. Personal Information may also be processed in paper form. We collect Personal Information that is necessary for us to provide you with the services offered on our site. To gain access to portions of our site, you will need to provide an email address and select a password. When you browse, reserve or purchase travel services through our site such information may be provided to the applicable vendors or other involved third parties to fulfill your travel arrangements, subject to the conditions described in the section "Sharing and Transfer of Personal Information" below.
In addition, if you are registered as a member of the Leaders Club program or registered as a user of this site, we may maintain the Personal Information about you in a guest profile. This site is designed to minimize the need for you to re-enter such information from the guest profile on the variety of reservation forms that appear when you use the site. Such information in the guest profile may be used by us to automatically fill in certain forms that appear when you browse this site for information and reservations. When you browse, reserve or purchase travel services through this site, such information may be provided to the applicable vendors or other involved third parties to fulfill your travel arrangements.
You may decide to share other information ("Other Information") with us about yourself (for example, demographic information like your age and gender) and your travel preferences and experiences.). If you share Other Information with us, we will use it to automatically record your travel preferences in reservations you make, tailor your experience at our site to your interests, and make more appropriate travel recommendations to you. You may still use our site to search for and purchase travel services, even if you choose not to share this type of information with us.
Opt-in and Opt-out
As part of the registration process and reservation process, we allow you to choose whether you wish to receive advertisements, updates and promotions from us. We hope you will find these items interesting and informative. Nonetheless, we will only send you this information if you let us know by clicking the respective box that you consent to the use of your email addresses to deliver to you our periodic updates highlighting hotel specials, promotions, contests, sweepstakes and other travel opportunities available on our site (“opt-in”) . If you do not opt-in to receive these communications, we will not send them to you, and even if you do opt in, you will have the opportunity at any time to opt out if you change your mind.
Purchasing, Booking Or Reserving Travel Services or Accommodations
Payment Information and Travel History
Whether or not you register with us, you will be able to book, reserve or purchase travel services or accommodations through our site. To do so, you must provide payment information to us - for example, your credit card specifics like card number, issuing bank, expiration date, cardholder name and billing address. If you have registered with us as part of our Leaders Club program, we will add this payment information to your traveler profile in order to fulfill future reservations. We will keep a history of all your reservations, bookings and purchases of travel services and accommodations through our site in your account information, unless you choose to edit your account information as described below in this policy.
Additional Products and Services
Sharing and Transfer of Personal Information
For the purposes described above, we may transfer and share your information, in compliance with applicable data privacy laws and on a need-to-know basis, with third parties including contractors, agents or data processors, some of whom may be located outside of your home jurisdiction, to enable such parties to provide services to us and to improve our service offerings to you. We will establish appropriate contract terms or other protections to appropriately safeguard such data. To ensure that all personal data transferred receive an adequate level of data protection within the meaning of the European Data Protection Directive (95/46/EC), the data processors have entered into contractual measures based on the European Commission model clauses or have taken other appropriate measures to address the adequacy requirement.
We may also use anonymous information supplied by you and other users during registration on our site with information about your use and others' use of our site. We will use this combined information to describe our user base, without reference to any specific individual, to potential partners, vendors, investors and advertisers. We will not share your Personal Information with any other users of our site, but we may use information we collect about your travel preferences and experiences to make recommendations to other users of our site. For example, if we know that you and other users of our site who have traveled to a particular destination had positive experiences at a hotel in that destination, we might recommend that hotel to others who will be traveling to that destination. We may also share aggregated statistical information about users of our site and our service and product offerings with others, including our vendors and partners. We will not link this statistical information to any Personal Information that can identify you as an individual.
Storage of Personal Information
The Personal Information you provide will be transferred and stored in a jurisdiction that may not provide an adequate level of protection to Personal Information equivalent to that provided by your home jurisdiction. We have engaged as our data processors the service provider Trust International Hotel Reservation Services GmbH, Unterschweinstiege 2-14, 60549, Frankfurt am Main, Germany for purposes of processing your reservation request, the service provider Zeta Interactive, 185 Madison Avenue, 5th Flr, New York, NY 10016, USA, for purposes of processing emails and online inquiries, and the service provider Medallia, 800 El Camino Real, Suite 400, Menlo Park, CA 94025, USA, for purposes of issuing post-stay guest surveys. We have taken appropriate measures with our data processors to ensure that all personal data transferred receive an adequate level of data protection within the meaning of the European Data Protection Directive (95/46/EC).
In addition, we may share information with additional service providers as described below.
In addition to the circumstances described above, LHW may disclose information you have provided if required to do so by law, court order, as requested by any government or law enforcement authority, or in the good faith belief that disclosure is otherwise necessary or advisable including, without limitation, to protect the rights or properties of LHW when we have reason to believe that disclosing the information is necessary to identify, contact or bring legal action against someone who may be causing interference with our rights or properties, whether intentionally or otherwise, or when anyone else could be harmed by such activities.
We maintain technical, electronic, and organizational security procedures to maintain the security of Personal Information, and safeguard Personal Information against unauthorized or unlawful processing and/or against accidental or unlawful loss, alteration, disclosure or access. Our security procedures include contractual terms with any contractors, agents or data processors that require such entities to protect the security and confidentiality of Personal Information in accordance with our standards.
It is your responsibility to safeguard any email or password that you have created or used in connection with this site, and to notify us if you ever suspect that the security and confidentiality of such email or password has been compromised in any way. You are solely responsible for any use of this site via your email and password.
Retention of Personal Information
We will maintain Personal Information for as long as we are required to do so by applicable law(s), or for as long as necessary for the purpose(s) described above for which it is processed. We will delete Personal Information when it is no longer needed and, in any case, upon expiration of the maximum storage term set forth by applicable law.
Notification of Changes
We may change this policy from time to time. If we decide to change this policy in a material way (for example, a change regarding disclosure of Personal Information), we will post notice of the change on our site and notify you via email at the address you have provided to us at least thirty (30) days before putting the change into effect. If we decide to change our policy in a less significant way, we will simply post notice of the change on our site at least thirty (30) days before putting the change into effect. Your continued use of our site after we make changes to this policy is deemed acceptance of those changes. If any proposed change is unacceptable to you, you may request to that we remove your Personal Information (and/or that of other individuals for whom you made your travel reservations) from our records.
Our site provides links to other sites. When you click on one of these links, you are leaving our site and entering another site that we do not control and for which we cannot be responsible. You should carefully review the privacy statements or policies on any other site that you visit because those privacy statements or policies will apply to your visit to that site and may be very different from our policy.
You can access, review, correct, change or delete your Personal Information that you have provided to us by logging into our site and visiting your account profile page. You can also object to the processing of your personal data for marketing purposes, or, for legitimate reasons, for other purposes, by contacting us at firstname.lastname@example.org or by writing to us The Leading Hotels of the World, Ltd., 485 Lexington Avenue, Suite 401, New York, NY 10017 , USA Attn: General Counsel.
The Leading Hotels of the World, Ltd.
485 Lexington Avenue, Suite 401
New York, NY 10017
Attn: General Counsel
The Leading Hotels of the World (France) SARL
Address: 6, rue Halévy, 75009 Paris, France
The Leading Hotels of the World, Ltd. (German branch office)
Address: Berliner Strasse 44, 60311 Frankfurt, Germany
The Leading Hotels of the World Ltd. (Milan branch office)
Address: Via Gustavo Fara, 20, 20124 Milano]
The Leading Hotels of the World, Ltd., Oficina de Representación en España
Address: Victor Andres Belaunde, 6 Of. 3. 28016 Madrid. Spain
Effective: September 29, 2016