PRIVACY POLICY

PRIVACY STATEMENT

We respect the privacy of all our customers and business partners, and treat personal information
(personal data) provided by you to us as confidential. We know that you are concerned how information about you is collected, processed, used and stored, and we appreciate you trusting that we will do so with every due care and diligence.

We have provided this Privacy Policy as an explanation of the information we collect, how we process and use it, and how the use of this information can benefit your experience on our web sites and products and services we provide.

1. WHAT INFORMATION ABOUT YOU DO WE COLLECT

In order for us to operate effectively and provide you with the best experiences with our services, we may request and collect information about you, whether as resort guest member or member, loyalty program member, web site visitors or you contacting us for any other purposes, that includes personal information that can identify you as an individual.

Your personal information can come to us via various channels, including but not limited to:

• When you browse and interact with our website and/or use any mobile apps that we may make available – such as make a booking via our Online Reservation system, make an inquiry, sign up for newsletter subscription or make brochure requests or download and use our mobile apps
• Through your use of our products and services – such as when you stay as a guest or visit the resort, restaurants or facilities managed by us
• When you submit enquiries to us or provide us with you feedback
• When you participate in our promotional offers, competitions or surveys
• As a member of our loyalty program or when your friends refer you to our programs
• From third parties – such as partners we work with or public databases – where you have provided your consent to the third party or to us to that information sharing taking place or where we have a legitimate interest to use the personal information in order to provide you with our products and services

The types of personal information that we collect and process may include, but not be limited to:

• Personal details, such as your name, gender, date of birth, nationality, passport and visa information, personal and work contact details (addresses, emails and telephone numbers)
• Payment and credit card information, such as bank accounts, name of cardholder, credit card number, credit card billing address and expiry date
• Guest stay information and lifestyle information, such as our Resort Club where you have stayed, arrival and departure dates, room preferences, leisure activities, names and ages of individuals, observation of your services preference, and other information necessary to fulfil special requests
• Information, feedback or content you provide regarding your interests and preferences
• Loyalty program member information, online account details, profile or password details
• Information from our security systems such as from our closed circuit television system, card key, internet login and firewalls
• Information relating to your use and interaction with our website and mobile apps
• Some of the personal information which you provide to us are considered “sensitive personal information” under the privacy and data protection laws in Ontario.
• Except where required by local laws, we do not knowingly collect personal information from our websites from any children or minors. As a parent or legal guardian, please do not allow your children or minors to submit personal information without your permission.

We may also collect non-personally identifiable information about you, such as internet log information or visitor behaviour patterns when you visit our websites on your use of our websites, communication preferences, travel habits, aggregated data relative to your stays, and responses to promotional offers and surveys. Please also refer to our Cookies policy.

2. HOW WE PROCESS AND USE YOUR INFORMATION

We may collect process and/or use the personal information which we collect in order to:

• Deliver our products and services to you – such as completing your reservations, sending you reservation confirmations, supplying the purchased goods and services, registering you for program membership, fulfilling a request for information, customising our services to your preferences, earning and redeeming rewards, keeping proper records of your transactions with us
• Communicate and provide marketing and promotion to you – such as sending you information and updates on our products and services and other products and services that we think may be of interests to you, including latest promotions, competitions, joint- and cross promotions with our business partners, response to enquiries, to send you important information regarding our website, changes to our terms, conditions and policies
• Develop and improve our services to you – such as performing market research, analytics and/or profiling, developing new products and services, improve the effectiveness of our website, your hotel experience, our various types of communications, advertising campaigns, and promotional activities
• Work and cooperate with third party parties to deliver our products and services to you – such as travel agents, group travel organisation, or anyone involved in the process of making your travel arrangements, credit card companies, airline operators and third party loyalty programs
• Maintain your safety and security as well as that of other guests and personnel – such as to make proper identification and verification in processing of transaction, implement security surveillance and access controls when you visit or stay at our hotels, and administer general record keeping
• Meet applicable legal and regulatory requirements
• Use it in other ways as required or permitted by law or with your consent
• We will only collect, process and/or use the personal information where we are satisfied that we have an appropriate legal basis to do so. This may be because (i) you have provided your consent, (ii) our use of information is necessary for providing the products and/or services you have requested, (iii) our use of your information is in our legitimate interest as a commercial organisation, such as to operate and improve our services (including for profiling and targeted advertising) and in a way proportionate and respects your privacy rights, and/or (iv) necessary compliance with applicable laws, regulations, court orders or other legal process.

3. KEEPING AND SAFEGUARDING OF PERSONAL INFORMATION

To the extent permissible by applicable law, we generally only keep your information for as long as is reasonably required for:

• The purposes for which that personal information was provided
• Ongoing business need, including record keeping, fraud prevention, or if we reasonably believe there is a prospect of litigation
• As necessary to meet legal, regulatory, tax or accounting needs
• We take reasonable steps to safely and securely delete, dispose of, anonymous and/or block personal information when we no longer need it.

INFORMATION SECURITY

We endeavour to protect your personal information we maintain and have implemented reasonable technical, organisational and administrative measures to keep your personal information safe and secure and to protect it against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We will review, monitor and update these security measures to meet our business needs, changes in technology and regulatory requirements.

INFORMATION SHARING

• Insofar as reasonably necessary for us in delivering our products and services to you and for the purposes set out in this Privacy Policy, we may share your personal information with the below parties: The specific kind of information we share will depend on your activities with us and only to the extent as required or permitted by law, and/or with your consent.
• Our group entities, Resort Club and residences managed and operated by us
• Our business partners and third parties involved in the delivery of our products and services to you – including those involved in a sale of all or part of our business operations or assets and those for business, operational and general administration
• Our marketing and advertisement partners
• Third party services providers which process data (including personal information) for us, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures
• Our agents, advisors, consultants, other third party suppliers and/or services providers to assist us to operate effectively and provide you with the best experiences with our services
• Other third parties when we have your consent or are otherwise permitted by law to do so

4. YOU CONTROL YOUR PERSONAL INFORMATION

You may always choose what personal information (if any) you wish to provide to us. Please note, however, some of our products and services to you may be affected if you choose not to provide certain details, for example, we cannot reply to you without a name or contact details.

If you provide us with your contact details (e.g. postal address, email address, telephone number or fax number), we may contact you to let you know about the products, services, promotions and events offered that we think you may be interested in. You can always choose whether or not to receive any or all of these communications by contacting us as described below. In addition to your agreeing to this Privacy Policy, we may also ask you to give us a separate consent before we send you with promotional information or to indicate how you would like to receive any communication (e.g. via email or regular mail). After you have indicated your preferences, you can always change them.

For additional information of questions regarding our policy, please contact us at: 1-888-765-9951