The Leading Hotels of the World Privacy Policy

Last Updated: August 2018

The Leading Hotels of the World, Ltd. (“LHW,” “we,” or “us”) is committed to protecting the information that you share with us online, and explaining how we collect, process, and share that information. We provide you with the notice below in English only to avoid any misinterpretations caused by a language translation. If necessary, please seek the proper advice, or avoid use of this website.

Summary of Key Issues

Collection We collect Personal Information about you that you provide to us or that we obtain while you are using the Site.
Protection We employ reasonable and current technical, administrative, and physical safeguards that are designed to prevent unauthorized access, maintain data accuracy, and designed to ensure correct use of Personal Information.
Use We use Personal Information to provide you with services from our Site, to build features that will make the services available on the Site easier to use, to contact you about these services, and to send advertisements, marketing material or other offers that we think might be of interest to you.
Marketing and Choices You have control on how we use Personal Information for marketing. You can exercise your control in any marketing communication, please click here for more information.
Sharing We share your Personal Information with our member hotels, affiliated companies, external service providers, third party vendors, agents, and otherwise as necessary to perform transactions with you and manage our business.
Cookies Our Site uses cookies and other similar technologies. To opt-out of advertising and certain other cookies, please click here.
Access and Data Subject Rights LHW understands that you may want to change, access, or delete your Personal Information. You may do so by accessing your profile or by contacting us here.
Cross-Border Data Transfers Our Site is operated in the United States. If you are located outside the US, your Personal Information will be transferred to the US, a jurisdiction that may not provide an equivalent level of protection as your home jurisdiction. Cross-border transfer is, therefore, necessary for the conclusion or performance of a transaction that you are requesting, and for the establishment, exercise, and defense of legal claims. For transfers originating in the European Union or Switzerland, LHW has self-certified adherence to the EU/Swiss-U.S. Privacy Shield Framework. To the extent permitted by local law, your use of the Site or provision of any Personal Information constitutes your consent to the cross-border transfer of Personal Information and the other activities identified in this Privacy Policy.
Children Persons under the age of 16 are not eligible to use any services on our Site.
Changes We will provide notice of any material changes to this Privacy Policy by posting a prominent notice on our Site and/or emailing you.
Contact Us Should you have any questions, concerns or comments, please click here. The Leading Hotels of the World, Ltd., 485 Lexington Avenue, Suite 401, New York, NY 10017, USA.


Scope and Information that this Privacy Policy Covers

This Privacy Policy applies to information collected on our websites, mobile applications, cloud-based services, or controlled widgets embedded in communication platforms with a link to this Privacy Policy (collectively, the “Site”). It covers how we collect, use, share, and otherwise process Personal Information as of the date that this Privacy Policy is posted. It does not apply to any other information collected by LHW through any other means. By “Personal Information,” we mean information that identifies or can identify you personally.

The Site contains links to third-party websites, including websites of our independently-owned member hotels. We do not own, operate or control the websites of those third parties, or of LHW member hotels, reservation agents, or travel sales associates. Accordingly, this Privacy Policy does not apply to any websites maintained or operated by unaffiliated third parties. When you click on those links, you will go to a third party website where you will be subject to that website’s privacy policy, which we encourage you to read. We are not responsible for the privacy practices of those other websites, including those of our independent member hotels, and we expressly disclaim any liability for their actions, including actions relating to the use and disclosure of Personal Information.

Personal Information We Collect About You

We collect your Personal Information on the Site to enhance the services we offer you, maintain and improve the Site, protect the security of you and our Site, comply with legal obligations, and inform you about other services and products that may be available through us, our affiliated companies, or through our marketing alliances. We collect Personal Information about you when you interact with or utilize services offered on this Site, such as:

  • Creating a profile with us;
  • Making reservations, accommodation requests and payments;
  • Joining The Leaders Club;
  • Creating and administering your Leaders Club account;
  • Consenting to marketing communications;
  • Applying for a job;
  • Submitting comments, reviews, or other user-generated content;
  • Connecting or interacting with us through social networks (e.g., Facebook, Google+, Twitter); or
  • Requesting customer or technical support.

Personal Information includes:

  • Name;
  • Postal or billing address;
  • E-mail address;
  • Telephone or mobile number;
  • Payment card information;
  • Government identification (e.g., passport identification to verify traveler identities);
  • Location via IP address;
  • Device being used (for our mobile site);
  • Cookies and similar technologies;
  • Member hotel stay information;
  • Your preferences regarding your member hotel stay (e.g. bed size, smoking versus non-smoking room); and
  • Other relevant data.

For Leaders Club members, we also collect date of birth, gender, Leaders Club account-related information, personal preferences relating to your member hotel stay, and information about your spend on rooms at LHW member hotels.

Even if you do not provide us with any Personal Information, we collect certain non-personal information about how you use our Site. This information cannot identify you and is used for statistical purposes only.

Use and Sharing of Personal Information

We only process and share your Personal Information, including sharing with service providers or other external entities, to the extent reasonably necessary to fulfill your requests and meet our legitimate business and legal objectives. When we disclose Personal Information to external entities to perform services for us, we establish by contract that they may access your Personal Information only for the purposes of performing those services. We may also use what we know about you to offer you other products and services. We may combine your online information with information collected from offline or online sources, or information we already have. We may also use and disclose certain Personal Information to our affiliated companies and others for any purpose allowed by law.
We generally process and may disclose your Personal Information to others to:

  • Provide you with products and services, including authenticating authorized users, and marketing our products and services;
  • Perform certain services or other transactions initiated by you;
  • Respond to your questions, complaints, or reviews of our product or services or those of our member hotels;
  • Send you communications about online transactions, product information, ads and promotions, electronic newsletters, or other notices you requested or offers tailored to you;
  • Enable our advertisers, where appropriate, to provide you with more personalized content, and track the effectiveness of certain advertising campaigns;
  • Comply with applicable law, obey judicial orders, cooperate with law enforcement authorities, or prevent any suspected illegal activities;
  • Help us run our business; or
  • For any other everyday business purposes, such as product development and Site administration.


Cross-Border Data Transfers

The Site is hosted by servers in the United States, as well as other countries, since we operate our business globally. We transfer Personal Information to various jurisdictions as necessary for the purposes described above, including to jurisdictions that may not provide the same level of data protection as your home country. We provide appropriate protections for cross-border transfers as required by law for international data transfers.

EU - U.S. and Swiss-U.S. Privacy Shield Framework

With respect to transfers originating from the European Economic Area (“EEA”) and Switzerland, LHW participates in the EU-U.S. and Swiss-U.S. Privacy Shield Framework (collectively, the “Framework”) as set out by the U.S. Department of Commerce regarding the collection, use and retention of Personal Information from the European Union and Switzerland. LHW’s participation in the Framework applies to Personal Information about employees received in the United States from the EEA, as well as Personal Information about corporate customers, corporate customers’ end-users, consumers and other third parties. LHW has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles will govern. LHW provides notice to all covered data subjects in the EEA and Switzerland about the collection, use, and disclosure of their Personal Information through internal company policies. For more information about our certification to the Framework, please click here: https://www.lhw.com/privacy-policy#privacy-shield-framework, or to visit the U.S. Department of Commerce site please click here: https://www.privacyshield.gov/welcome. Data subjects in Europe or others with inquiries or complaints should reach out to the LHW Privacy Shield Contact at privacy@lhw.com.

Processing Basis and Consequences

Certain jurisdictions, including those in Europe, require the identification of the legal grounds for the collection, use, sharing, and other processing of Personal Information. LHW relies on the following legal grounds for its collection, use, sharing, and other processing of Personal Information as described in this Privacy Policy:

  • Necessary to provide information or otherwise carry out the performance of a contract with you as an individual;
  • Our legitimate interests, including:
    • Performance of contracts with our member hotel owners, managers or operators;
    • Implementation and operation of a group-wide matrix structure and group-wide information sharing;
    • Customer relationship management and other forms of marketing and analytics;
    • Fraud prevention, misuse of company IT systems, or money laundering;
    • Physical, IT, and network perimeter security;
    • Internal investigations; and
    • Intended mergers and acquisitions.
  • Compliance with legal obligations and/or defense against legal claims, including those in the area of labor law, social security, and data protection, tax, and corporate compliance laws.
  • Protection of the vital interests of any individual;
  • Performance of a task carried out in the public interest or in the exercise of official authority vested in LHW; and
  • Consent, as permitted by applicable law.

Providing us with Personal Information is voluntary, but your refusal to provide Personal Information for the above-mentioned purposes may affect our ability to fulfill our contractual obligations or to provide you with The Leaders Club benefits or other LHW Site benefits, services, information, and or material requested by you. Even so, unless otherwise specified, not providing your Personal Information will not result in any direct legal consequences for you.

Your Rights Concerning your Personal Information

You have the following choices regarding our use and disclosure of your Personal Information:

  • Marketing Communications. If you no longer wish to receive any marketing communications, remain on a mailing list to which you previously subscribed or receive any other communication from LHW, please follow the unsubscribe link in the relevant communication. Even after you opt-out or update your marketing preferences, we may still contact you for transactional or informational purposes. These include, for example, customer service issues, surveys, or any questions regarding a specific reservation.
  • Cookies and Similar Technologies. Please review your browser or computer settings for certain cookies and see below to exercise certain choices regarding cookies.

You are not required to provide all Personal Information identified in this Privacy Policy to use our Site, but certain aspects of our Site will not be available to you. However, you can use our services without consenting to non-essential cookies or direct marketing emails; the only consequence is that we will communicate less to you regarding our member hotels, The Leaders Club, and our services, we may not be able to provide the support you seek, and you may miss out on attractive promotions and news about our member hotels, The Leaders Club and our services.

Europe and certain other non-US jurisdictions maintain local data protection regulations that confer certain data protection rights on individuals. LHW will address those rights where required by applicable laws. Note that if you are an employee of an LHW member hotel, and we obtain access or otherwise process your Personal Information in that context, you should contact your employer which will be in the best position to respond to your inquiry. If applicable, and you wish to exercise any of these rights, please contact us as set out below.

  • Right of access: You have the right to obtain from us confirmation as to whether or not Personal Information concerning you is processed, and, to request access to the Personal Information. The access information includes, among other things, the purposes of the processing, the categories of Personal Information concerned, and the recipients or categories of recipient to whom the Personal Information have been or will be disclosed. This is not, however, an absolute right, and the interests of other individuals may restrict your right of access. You may have the right to obtain a copy of your Personal Information undergoing processing.
  • Right to rectification: You have the right to obtain from us the rectification of inaccurate Personal Information about you. Depending on the purposes of the processing, you have the right to have incomplete Personal Information completed, including by means of providing a supplementary statement.
  • Right to erasure (right to be forgotten): Under certain circumstances, you have the right to obtain from us the erasure of Personal Information concerning you, and we may be obligated to erase that Personal Information.
  • Right to restriction of processing: Under certain circumstances, you have the right to obtain from us restriction of processing your Personal Information. In that case, your data will be marked and may only be processed by us for certain limited purposes.
  • Right to data portability: Under certain circumstances, you have the right to receive the Personal Information about you, which you have provided to us, in a structured, commonly used and machine-readable format, and you have the right to transmit that data to another entity without hindrance from us.
  • Right to object: Under certain circumstances, and at any time, you have the right to object, on grounds relating to your particular situation, to the processing of your Personal Information by us, and we can be required to no longer process your Personal Information.

Where permitted by applicable law, you also have the right to lodge a complaint with a competent data protection supervisory authority.

Security of Your Information

We maintain reasonable 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. While we strive to protect your Personal Information, we cannot ensure the security of the information you transmit. It is your responsibility to safeguard any email or password that you have created or used in connection with The Leaders Club and any LHW 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 your The Leaders Club account via your email and password.

Retention and Storage of Your 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/or take steps to properly anonymize it so that you can no longer be identified from it (unless we need to keep your information to comply with legal or regulatory obligations to which LHW is subject) and, in any case, upon expiration of the maximum storage term set forth by applicable law.

Children

LHW does not knowingly collect Personal Information from children under the age of 16, and users under the age of 16 should not submit any Personal Information to LHW. If LHW has actual knowledge that Personal Information about a child under 16 years old has been collected, then LHW will take the appropriate steps to delete this Personal Information.

Cookies And Similar Tracking Technologies

Information Collected Through Technology. Information is also obtained in other ways through technology. Some of this information may be linked to you personally. In accordance with applicable law, LHW uses and allows third parties to use essential and non-essential cookies, online tracking tools, web beacons, and similar technologies (collectively, “cookies”) on our Site. We process this information to help our Site function correctly, and better understand the needs of our customers.

Device Information. Depending on the permissions you’ve granted and other factors, we may receive information about your location and your mobile device when you download or use apps created by our Sites, including a unique identifier for your device. Examples of the device information we collect include:

  • Attributes such as the operating system, hardware version, device settings, battery and signal strength, and device identifiers.
  • Certain device locations, including specific geographic locations, such as through GPS, Bluetooth, or WiFi signals are gathered if you enabled the functionality within your device settings.
  • Connection information such as the name of your mobile operator or ISP, browser type, language and time zone, mobile phone number and IP address.

Most mobile devices allow you to turn off location services, and we encourage you to contact your device manufacturer for detailed instructions on how to do that.

Cookies on our Site generally fall into the following categories:

  • Strictly Necessary Cookies: These are required for the operation of our Site. They include, for example, cookies that enable you to log into secure areas. These cookies are session cookies which are erased when you close your browser.
  • Analytical/Performance Cookies: These allow us to recognize and count the number of users of our Site and see how such users navigate through our Site. This helps to improve how our Site works, for example, by ensuring that users can find what they are looking for easily. These cookies are session cookies which are erased when you close your browser.
  • Functional Cookies: These improve the functional performance of our Site and make it easier for you to use. For example, cookies are used to remember that you have previously visited the Site and asked to remain logged into it. These cookies are session cookies which are erased when you close your browser.
  • Targeting Cookies: These record your visit to our Site, the pages you have visited and the links you have followed to recognize you as a previous visitor and to track your activity on the Site and other websites you visit. These cookies qualify as persistent cookies, because they remain on your device for us to use during a next visit to our Site. You can delete these cookies via your browser settings. We will not collect these cookies from individuals in Europe without notice.

Use of Cookies. We advertise in a number of ways, including online through managed social media presences, and on other unaffiliated sites and mobile applications. To understand how our advertising campaigns are performing, we may collect certain information via cookies on our Site through our advertising service providers. The information we collect includes IP addresses, the number of page visits, pages viewed via our Site, search engine referrals, browsing activities over time and across other websites following your visit to our Site or applications, and responses to advertisements and promotions on the websites and applications where we advertise.

We also use certain information to identify new visitors to our Site, recognize returning visitors, advertise on other websites and mobile applications not affiliated with us, analyze the effectiveness of our advertisements, better understand our audience, customers, or other Site visitors, and determine whether you might be interested in new products or services.

Controlling Our Tracking Tools. Your browser may give you the ability to control cookies. How you do so, however, depends on your browser and the type of cookie. Certain browsers can be set to reject all browser cookies. If you configure your computer to block all cookies, you may disrupt certain web page features, and limit the functionality we can provide when you visit or use our Site. (e.g., we will not be able to provide you with searches that you have asked us to save). You can change your cookie settings at any time. Some browsers have a “Do Not Track” feature that lets you tell websites that you do not want to have your online activities tracked. These browser features are still not uniform, so we are not currently set up to respond to those signals.

Controlling Online Interest-Based Ads. We sometimes work with online advertising vendors to provide you with relevant and useful ads. This may include ads served on or through our Site. This may also include ads served on other companies’ websites. These ads may be based on information collected by us or third parties. For example, your postal code may be used to target an ad for people in your area. These ads may also be based on your activities on our Site or on third-party websites.

For more information about our ad service provider and its cookies, including information about how to opt out of these technologies, you may visit http://optout.aboutads.info In addition, users may prevent Google’s collection of data generated by your use of the Site (including your IP address) by downloading and installing a Browser Plugin available at https://tools.google.com/dlpage/gaoptout?hl=en.

Changes to our Privacy Policy

We may change this policy from time to time. If we make any material change in how we collect, use, disclose, or otherwise process Personal Information, we will prominently post notice of the change on our site for at least thirty (30) days before putting the change into effect. Where required to do so by law, we may seek your prior consent to any material changes we make to this Privacy Policy. Otherwise, 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 that we remove your Personal Information (and/or that of other individuals for whom you made your travel reservations) from our records.

Contact Us

If you have any questions or comments regarding this Privacy Policy or our privacy practices in general, please contact us as detailed below. You may also have a right to lodge a complaint with a supervisory authority.

Email: privacy@lhw.com

Mailing Address:

The Leading Hotels of the World, Ltd.
485 Lexington Avenue, Suite 401
New York, NY 10017
USA

Attn: General Counsel

Contact Details of the EU Representative

France
The Leading Hotels of the World (France) SARL
Address: 6, rue Halévy, 75009 Paris, France
Tel: (33-1) 53-67-10-10
E-mail: privacy@lhw.com

Germany
The Leading Hotels of the World, Ltd. (German branch office)
Address: Berliner Strasse 44, 60311 Frankfurt, Germany
Tel: (49-69) 138-85-100
E-mail: privacy@lhw.com

Italy
The Leading Hotels of the World Ltd. (Milan branch office)
Address: Via Manuzio, 7, 20124, Milan, Italy
Tel: (39-02) 669-86131
E-mail: privacy@lhw.com

Spain
The Leading Hotels of the World, Ltd., Oficina de Representación en España
Address: C/ Orense 85 – Edificio Lexington, 28020 Madrid, Spain
Tel: (34-91) 55-91-750
E-mail: privacy@lhw.com

United Kingdom
The Leading Hotels of the World, Ltd.
Address: Mortimer House, 37-41 Mortimer Street, Fitzrovia, London WIT 3JH, England
Tel: (44-20) 7290-1000
E-mail: privacy@lhw.com


The Leading Hotels of the World, Ltd.

PRIVACY SHIELD WEBSITE PRIVACY POLICY

EUROPEAN UNION PERSONAL DATA



EU-U.S. Privacy Shield Framework

The Leading Hotels of the World, Ltd. in the United States (“LHW US”) participates in the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks (collectively, the “Framework”). LHW US’s participation in the Framework applies to Personal Information received in the United States from the European Union (“EU”) and Switzerland about employees (“European Employee Personal Information”), individual contacts of business customers, members of The Leader’s Club, and guests of LHW-partnered hotels (“European Customer Personal Information”) (collectively, “European Personal Information”). We are committed to subjecting such European Personal Information to the Framework to the extent that we have received it in reliance on the Framework, including its Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. To learn more about the Framework, visit the U.S. Department of Commerce’s Privacy Shield List here.

European Employee Personal Information Collection, Use, and Disclosure

LHW US provides its EU Employees notice about the collection, use, and disclosure of their European Employee Personal Information through internal company policies.

European Customer Personal Information Collection, Use, and Disclosure

LHW US collects and processes the following categories of European Customer Personal Information: name, email and mailing addresses, telephone number(s), credit card information, passport number, booking information (such as name of hotel, reservation dates, type of room), cookies and device information (e.g., IP address and other device identifiers). European Customers may voluntarily share with LHW US other information, such as demographic information like age and gender, and travel preferences and experiences.

LHW US will use and otherwise process European Customer Personal Information in the United States for the following purposes:

  • To process and manage reservations;
  • To better market our services to EU Customers;
  • To provide customer service to EU Customers;
  • To enroll Leaders Club members and manage Leaders Club memberships;
  • Data hosting;
  • Information technology support; and
  • Data analytics.

Rights of EU Data Subjects

If you are an EU data subject, you have the right to access your own European Personal Information subject to certain limitations, such as where the legitimate rights of other persons would be infringed or where the burden or expense of providing access would be disproportionate. If you wish to exercise such rights, please contact us as described below.

Choices of EU Data Subjects

Individual Customers have the right to exercise choice (opt-out) from our use of their European Customer Personal Information for direct marketing purposes. To exercise this right, please follow the instructions in any direct marketing message you may have received. We do not otherwise use or disclose European Customer Personal Information in a manner that is subject to choice requirements under the Framework. We describe the choices for European Employee Personal Information through internal company policies.

Recourse, Enforcement, and Liability

Please contact us as specified below if you have any questions, need access to your European Personal Information, or otherwise need assistance. We remain responsible for our collection, use and disclosure of European Personal Information in accordance with the Framework. We also are responsible for third party agents that are processing such data on our behalf, unless we prove that we are not responsible for the event giving rise to the damage. In certain situations, we may be required to disclose European Personal Information in response to lawful requests by public authorities, including meeting national security or law enforcement requirements.

If you have an unresolved concern about European Personal Information that we have not addressed satisfactorily, we have committed to cooperate with the panel established by the EU Data Protection Authorities and the Swiss Federal Data Protection and Information Commissioner (FDPIC) to serve as our independent dispute resolution body for the Framework. We are also subject to the investigatory and enforcement powers of the Federal Trade Commission with respect to the Framework. In addition, under certain conditions, more fully described on the Privacy Shield website, EU data subjects may invoke binding arbitration for non-monetary issues when other dispute resolution procedures have been exhausted.

Contact Us

Please contact us here if you have any questions related to the Privacy Shield, wish to exercise your rights of access, or wish to seek other assistance as described above.

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