- we will not collect personally identifiable information like your name, email, mailing address or telephone number (“Personal Information”) without your knowledge or 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. 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.
You can always visit our site without revealing who you are or providing any Personal Information. When you visit our site or visit our site through a linking site, we do collect usage information, such as your IP address, (“session data”), but it is stored using pseudonyms only and is not linked to you as an individual. We use session data to better understand things such as how our site is navigated, how many visitors arrive at specific pages, the length and frequency of stays at our site, the variety of searches of our site’s database, the types of browsers and computer operating systems used by our visitors, and the Internet Protocol addresses from which our visitors connect to our site. We use this information to improve our site content and ease of use. If you have configured your browser to accept cookies, as described below, then you may opt-out if you do not want us to collect and use such session data as described above by sending an email to firstname.lastname@example.org.
If you decide to register with us or to make a reservation on this site, we will collect Personal Information about you that you voluntarily share with us. We collect Personal Information that is necessary for us to provide you with the services offered on our site. The 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. As mentioned, this Personal Information may include in particular your name, email and mailing address, telephone number(s), credit card information and passport number. You will provide an email address and select a password that will be required to gain access to portions of our site.
In addition, if you are registered as a member of the Leaders Club program or registered as a user of the site, LHW may maintain 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 LHW to automatically fill in certain forms that appear when you browse this site for information and reservations, and when you utilize any other sites linked from this site. When you browse, reserve or purchase travel services through such sites, 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 (for example, participation in airline/hotel/car-rental loyalty or awards programs and applicable membership numbers, meal requests and ticketing options). 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, we give you important choices (“opt-in”) about advertisements, updates and promotions. We hope you will find these items interesting and informative. Nonetheless, we will only send you this information if you register in advance and let us know by clicking the respective box that you would like us to use your email addresses to deliver to you our periodic updates highlighting hotel specials, promotions, contests, sweepstakes and other travel opportunities available on our site . If you do not opt-in to receive these communications about our site, 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.
Storage of Personal Information
The Personal Information you provide will be stored in a jurisdiction that may not provide a 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, Unterschweinstiege 2-14, 60549, Frankfurt am Main, Germany for purposes of processing your reservation request, the service provider ClickSquared, 200 West Street, Suite 300, Waltham, MA 02451 for purposes of processing emails and online inquiries, the service provider Medallia, 800 El Camino Real, Suite 400, Menlo Park, CA 94025 for purposes of issuing post-stay guest surveys. In addition, we may share information with additional service providers as described below.
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 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.
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.
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. 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.
Sharing of Personal Information
We may periodically share your information, in compliance with applicable data privacy laws, 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. We may also anonymously combine 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.
Additional Products and Services
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) 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. 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.
The Leading Hotels of the World, Ltd.
99 Park Ave.
NY 10016 USA
Attn: General Counsel
Effective: October 15, 2011