Data Transfers And Processing - Auberge Resorts Collection

ANONYMIZED AND AGGREGATED DATA

Anonymization is a data processing technique that removes or modifies personal 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 anonymize include, contact information, survey information, and demographic information.

HOW YOUR PERSONAL INFORMATION IS PROCESSED

Personal 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 Personal information may be processed in the following ways

1. To provide you Services. Your Personal Information may be used to provide the following Services, including:
   • Facilitate communication between you, ARC Properties, and AR. Personal 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
   • Completed 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.  Personal 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 Personal Information is used by AR and ARC Property to confirm your reservation and provide Services.
4. To communicate with you. Your Personal 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 any 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:
   • 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 that you have requested
   • Marketing and Targeted Advertising.  Personal 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 Personal 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 Personal Information is processed for quality control and for staff training to enhance quality of Services. If your Personal 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, securing the security of ARC Properties may not be possible.
7. To enhance your experience. Your Personal 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 Personal 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 Personal Information may be disclosed for any purpose you consent to.

The following chart summarizes how the collected Personal Information is used:

 

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

 

Your personal 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 Personal Information with third-parties. You may opt-out of having your Personal Information shared with third-parties, or allowing the use of your Personal Information for any purpose that is incompatible with the purposes for which the Personal Information was collected or subsequently obtained through your authorization. If you choose to limit the use of your Personal Information, 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.

Section & Purpose of Processing	Legal Basis for Processing
(1) To provide you Services (2) To provide you with personalized Services(3) Third-party booking (4) To communicate with you (5) To ensure quality(6) To ensure security	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.
(7) To enhance your experience (8) To facilitate corporate acquisitions, mergers, or transactions	Based on the 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.
(6) To ensure security	Based on the legal obligations of AR or ARC Properties. Obligations, the public interest, or in your vital interests.
(7) To enhance your experience (9) To engage in marketing activities (10) For any purpose	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.