Data Transfers And Processing | Auberge Resorts Collection

ANONYMIZED AND AGGREGATED DATA

 

Anonymization is a data processing technique that removes or modifies your information so that it cannot be associated with a specific individual. Except for this section, none of the other provisions of this Privacy Notice applies to anonymized or aggregated customer data (i.e. information about the customers (i.e., you) that when combined together no longer identifies or references an individual customer).

The anonymized or aggregate customer data may be used for any business purpose, such as to better understand customer needs and behaviors, improve the Services, conduct business intelligence and marketing, and detect security threats. Analytics may be performed on anonymized data or enable analytics provided by third-parties.

Types of data that may be anonymized include contact information, survey information, and demographic information.

 

HOW YOUR INFORMATION IS PROCESSED

 

Your information is used to communicate with you and to provide the products or services you have requested. It is also used to conduct business operations, to improve products and Services offered by AR or by ARC Properties, and to send you marketing offers that may interest you.

Your information may be processed in the following ways

1. To provide you Services. Your information may be used to provide the following Services, including:
   • Facilitate communication between you, ARC Properties, and AR. Your information may also be used to understand how customers use the Services in order to improve the experience and the services offered.
   • Facilitate reservations, payment, sending information pertaining to your stay, to assist you with your requests, and to provide you with pertinent information.
   • Complete your reservation and stay.
   • Send you the electronic receipt of your bills, if requested by you.
   • AR and ARC Properties may not be able to provide you with the Services without such information.
2. To provide you with personalized service.Your information is used to improve and tailor the Services to your preferences. Personalized Services may not be available without such information.
3. Third-Party Booking.If you use a third-party to book a reservation, your information is used by AR and ARC Property to confirm your reservation and provide Services.
4. To communicate with you.Your information is used to respond to you or to communicate with you about the Services. For example, an ARC Property may contact you to inform you of changes to your booking or to suggest activities to add to your itinerary. The types of communications that are sent depend on your use of the Services offered by an ARC Property and can include:

Personal Information Category (see “Collection of Personal Information” heading above for more information)	Sources of Personal Information	Purpose of Collecting Personal Information	Disclosure of Personal Information (see “Sharing Your Personal Information With Other Parties” heading below for more information)
(A) Identifiers such as Personal Identification Information	Contact Information; Billing Information; Customer Services Information; Traveler Information; Survey Information.	Sections 1, 2, 3, 4, 5, 6, 7, 8, 9, 10	– Third-party payment processors – Third-party booking agents – Service providers – Law enforcement agencies, as required by applicable laws
(B) Any categories of personal information described in Cal. Civ. Code § 1798.80.	Contact Information; Billing Information; Customer Services Information; Survey Information; Demographic Information; Traveler Information; Protected and Sensitive Information	Sections 1, 2, 3, 4, 5, 6, 7, 8, 9, 10	– Third-party payment processors – Third-party booking agents – Service providers – Law enforcement agencies, as required by applicable laws
(C) Customer records such as signature	Contact Information; Billing Information;	Sections 1, 2, 3, 4, 5, 6,  7	– Third-party payment processors – Third-party booking agents – Service providers – Law enforcement agencies, as required by applicable laws
(D) Protected classifications under California and federal law including gender, age, and citizenship	Demographic Information; Traveler Information; Protected and Sensitive Information; Health Information	Sections 1, 2, 4, 6, 7	– Service provider – Law enforcement agencies, as required by applicable laws
(E) Commercial information such as records of services purchased, obtained, or considered	Customer Services Information; Survey Information; Personal Information Received From Third-Parties	Section 1, 2, 3, 4, 5, 7, 9, 10	– Third-party payment processors – Third-party booking agents – Service providers – Law enforcement agencies, as required by applicable laws
(F) Biometric information	Biometric Information	Sections 1, 2, 5, 6, 7	– Service providers – Law enforcement agencies, as required by applicable laws
(G) Usage Data and Online Identifiers	Online Interactions	Sections 1, 2, 3, 4, 5, 6, 7, 9, 10	– Third-party booking agents – Service providers – Law enforcement agencies, as required by applicable laws
(H) Audio Electronic visual, thermal, olfactory, or similar information	Biometric Information; Audio and Visual Information	Sections 1, 2, 5, 6, 7	– Service providers – Law enforcement agencies, as required by applicable laws
(I) Professional or employment-related information	Contact Information	Sections 1, 2, 4, 5, 6, 7, 8, 10	– Third-party payment processors – Third-party booking agents – Service providers – Law enforcement agencies, as required by applicable laws
(J) Inferences about preferences, characteristics, predispositions, etc.	Contact Information; Billing Information; Customer Services Information; Survey Information; Demographic Information; Traveler Information; Protected and Sensitive Information; Health Information; Personal Information Received from Third-Parties;  Audio and Visual Information; Biometric Information; Online Interactions	Sections 1, 2, 4, 5, 7, 8, 9, 10	– Service providers – Law enforcement agencies, as required by applicable laws

 

• Confirmations and Itinerary Communications.You may receive communications to confirm your booking or to help you create an itinerary for your stay, such as communications containing information about local sites, services, places of interest and other things to do.
• Text Alerts.You may receive text message alerts related to information, services, marketing, or special offers you requested.
• Marketing and Targeted Advertising.Your information is used to communicate with you about promotions and marketing offers that may be of interest to you. Cookies and other similar technology are also used to learn about your interests and to send you more relevant advertising.
• Guest Surveys.If you stay at an ARC Property, you may receive a guest survey to give feedback about your experience. These surveys are used to learn about how Services can be improved.

 

If your information is not processed for such purposes then the response to your requests may not be possible, which may interrupt your enjoyment of the Services. While you may be able to opt-out of marketing-related communications, you may not be able to opt-out of receiving critical Service-related communications, such as confirmation of your itinerary and appointments for activities that you have signed-up to participate in at ARC Property where you are staying.

5. To ensure quality. Your information is processed for quality control and for staff training to enhance quality of Services. If your information is not processed for quality control purposes, you may experience issues with the Services, such as not considering the implementation of your suggestions.
6. To maintain security. The audio and visual images are also collected from cameras installed in public areas at AR and in ARC Properties. At AR and in some ARC Properties, biometric information may also be collected. Without such information, ensuring the security of ARC Properties may not be possible.
7. To enhance your experience. Your information is also processed to provide a personalized experience and implement the preferences you request. Without such processing, the assurance of your continued enjoyment of part or all of the personalized Services may not be possible.
8. To facilitate corporate acquisition, mergers, or transactions. Any information that you have provided may be disclosed, as necessary, in the context of corporate acquisitions, mergers, or other corporate transactions. You have the option of asking us to delete your information if you do not wish to have your information processed for such purposes.
9. To engage in marketing activities. Based on your communication preferences, marketing communications (e.g., emails or mobile notifications) may be sent to you to inform you about the offers, events, or partner events; to deliver targeted marketing; and to provide you with promotional offers. Marketing will be conducted in accordance with your advertising marketing preferences and as permitted by applicable law.
10. For the purpose that you have consented to. Your information may be disclosed for any purpose you consent to.

The following chart summarizes how the collected information is used:

Your information will not be used for any other purposes without your permission, other than for those purposes disclosed herein. From time to time, and as required under the applicable law, your permission may be requested to share your information with third-parties. You may opt-out of having your information shared with third-parties, or allowing the use of your information for any purpose that is incompatible with the purposes for which your information was collected or subsequently obtained through your authorization. If you choose to limit the use of your information so, certain features of the Services may not be available to you.

EEA Data Subjects

 

Legal Basis for Processing your Information

For individuals who are EEA Residents at the time their personal data is collected, AR and ARC Properties rely on the legal basis for processing your information under Article 6 of the EU General Data Protection Regulation (“GDPR”). Generally, your data is processed only where there is a legal requirement to process such information, where processing is necessary to perform any contracts that you have entered for the Services (or steps taken at your request prior to entering into the contract), for the legitimate interests in operating the business or to protect AR, ARC Properties, or your, property, rights, or safety, or where you have given your consent to do so. The below list describes the purpose of processing with the corresponding legal basis for processing.

 

(1) To provide you Services (2) To provide you with personalized Services® Third-party booking (4) To communicate with you (5) To ensure quality (6) To ensure security     (7) To enhance your experience (8) To facilitate corporate acquisitions, mergers, or transactions           (6) To ensure security         (7) To enhance your experience (9) To engage in marketing activities (10) For any purpose

Based on AR or ARC Property’s contract with you or to take steps at your request prior to entering into a contract with AR or ARC Property’s to provide you the Services.           Based on legitimate interests. When your personal data is processed for legitimate interests, AR or ARC Properties consider and balance any potential impact on you and your rights under data protection laws.       Based on the legal obligations of AR or ARC Properties. Obligations, the public interest, or in your vital interests.     Based on your consent.

 

Right to Withdraw Consent

If you have given your consent in relation to particular processing or activities, you can withdraw your consent at any time by methods described in the Contact Information section below.

SHARING YOUR INFORMATION WITH OTHER PARTIES

Your information is allowed to be only accessed by those who require access to perform their tasks and duties, and is only shared with third-parties in accordance with your consent or to complete the transaction of a service you have requested or authorized. Your information is also shared with AR and ARC Properties’ affiliates, vendors and third-party service providers to process on behalf of AR and ARC Properties. Your information to third-parties is never rented or sold without your explicit written consent. Your information is shared with third parties in the following circumstances:

• With service providers under contract who help with parts of the business operations. The agreements with such service providers require these service providers to only use your information in connection with the services they perform for AR or ARC Properties and prohibit them from selling your information to anyone else. Examples of the types of service providers with whom your information may be shared include (other than those mentioned above):
  • Accounting
  • Booking
  • Cloud storage
  • Concierge Services
  • Customer Support
  • Data analytics
  • Document repository services
  • Information Technology
  • Internet (e.g. ISPs)
  • Network infrastructure
  • Payment processing
  • Revenue Management
  • Sales
  • Social Media
  • Website Management
• With companies or other entities that could merge or acquire AR or any of the ARC Properties. If there is going to be a change in how your information is going to be processed, you will receive prior notice of any such change.
• With companies or other entities that purchase AR or ARC Properties pursuant to a court-approved sale or where we are required to share your information pursuant to insolvency law in any applicable jurisdiction.
• With professional advisors who provide banking, legal, compliance, insurance, accounting, or other consulting services in order to complete third party financial, technical, compliance and legal audits of operations or otherwise comply with the legal obligations of AR or ARC Properties.

Other Uses and Disclosures OF YOUR INFORMATION

Your information may be used or disclosed as necessary or appropriate, such as: (a) to comply with applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including authorities outside your country of residence and to meet national security or law enforcement requirements; (d) to enforce AR or ARC Properties’ terms and conditions; (e) to protect AR or ARC Properties’ operations; (f) to protect the rights, privacy, safety or property of AR or ARC Properties, you or others; and (g) to allow AR or ARC Properties to pursue available remedies or limit the damages that AR or ARC Properties may sustain.