Privacy Policy for Guests

1. Introduction

This privacy policy (the “Policy”) lets you know how Claremont Hotel, (“Claremont””, “us’, or “we”) collect, use, and share your personal information. This Policy gives effect to our commitment to protect your personal information and has been adopted by Claremont, as defined in this Policy.

We use your personal information in order to fulfill our commitment to providing an unparalleled guest experience in connection with all of your interactions with Claremont (the “Purpose”). As part of that undertaking, we are committed to safeguarding the privacy of the personal information that we gather.

As one of our guests or someone else with whom we interact, you understand and agree that we may collect, use, and share your personal information in accordance with this Policy.

2. The Application of this Policy

This Policy applies when you interact with Claremont either through our website - including Claremontsobe.com and other various booking sites - (collectively, “Websites”), our mobile applications (collectively the, “Application”), in person, such as when you visit us at the Claremont Location (as defined below), or when you communicate with us by phone, text, direct message, social media, or other similar functionality.  This Policy also applies to the personal information about you that we receive from a third party, unless specifically covered by such third party’s privacy policy or Claremont’s Privacy Policy for Employees.

While this Policy is intended to describe the broadest range of our information collection, processing and sharing activities globally, some activities may be more limited in some jurisdictions based on the particular laws or regulations in those regions. For example, the laws of a particular country/region may limit the types of personal information we can collect or the manner in which we process that information. In those instances, we adjust our internal policies and/or practices to reflect the requirements of local law.

3. Information We May Collect

We collect and process your personal information in order to provide you the best experience possible when you interact with us. The information we collect may vary by jurisdiction/region or by your preferred method of interaction with us. The categories of personal information that we may collect include:

• Contact and Identification Information: We may collect information such as your name, contact details (e.g. phone numbers, address, or email) professional title, employer or professional affiliations, and passport and visa information;
• Account Information and Marketing Preferences:  We may also collect information on your marketing preferences;
• Stay and Purchase Information: We may collect information such as dates of arrival and departure, goods and services purchased or utilized at the Claremont Location or on the Website or Application, physical and digital room key usage, special requests made, service and stay preferences (including room and vacation preferences), telephone numbers dialed and faxes sent, calls or messages received, and any feedback or content you provide to us regarding your stay. We may also collect information through the use of closed circuit television systems, internet systems (including wired or wireless networks, smart or mobile device, or your location), and other security and technology systems;
• Internet & Network Activity: We may collect the Internet Protocol (“IP”) address automatically assigned to your computer or device each time you interact with us online. We also use cookies and related technologies to collect information related to how you interact with our Website, Applications, and online content. We may collect the date and time of your visit, the pages you access and the amount of time you spend on each page, the type of Internet browser you use, your device’s operating system, your search terms on the Website, the URL of any website that you visited before and after visiting our Website (including the advertisement that referred you to our Website), and whether you click or interact with our digital content and advertising on other sites. When you access the Application or the mobile version of the Website, we collect your device, your device’s unique identifier, your mobile network information, and the type of browser you use. For information about how Claremont uses cookies and related technologies and how to disable such cookies and related technologies, Please see Section 8.2 below;
• Payment and Credit Information: We may collect credit card and other payment method details. In limited cases, we may also collect information relating to the credit of customers;
• Location Information: We may automatically collect information about your precise geolocation when you access the Website or Application to the extent permitted by applicable law.  We may also collect information about your general location using your IP address and your zip code;
• Demographic Information: We may collect demographic information, such as your gender, nationality, age, and date and place of birth;
• Biometric and Health-related Information: We may collect health-related information you provide us to fulfill special requests (e.g., health conditions that require specific accommodation or services), or biometric information, such as information used for facial recognition;
• Audio and Visual Information: We may record our customer service calls and security footage of our properties, which may include your voice and/or image;
• Preferences and Inferences: We may collect your preferences or make inferences about you, reflecting what we believe to be your preferences, characteristics, and predispositions, based on other personal information we have
• Device Content: With your permission, we may collect information relating to the content on your device. For more information, see Section 9.

There may be instances in which the personal information that you provide to us or that we collect is considered Sensitive Personal Information under the privacy laws of some countries or regions. Those laws define “Sensitive Personal Information” to mean personal information from which we can determine or infer an individual’s racial or ethnic origin, political opinions, religious beliefs or other beliefs of a similar nature, membership in a trade union or professional association, physical or mental health or condition, medical treatment, genetic data, biometric information, and information about an individual’s sexual life or sexual orientation. In some very rare instances, financial records may constitute Sensitive Personal Information where you are located. If we rely on consent to process your Sensitive Personal Information, you have the right to withdraw that consent at any time. We only process Sensitive Personal Information in your jurisdiction if and to the extent permitted or required by applicable law.

When you agree to this Policy you are, to the extent required under your local law, granting your express and written consent to the processing of any personal information that you provide to Claremont that is considered to be Sensitive Personal Information or financial information. Save to the extent required by law, you are not obliged to provide Claremont with any of your Sensitive Personal Information, and should you choose not to, this will not prevent you from purchasing any products or services from Claremont.

4. How We Collect Your Personal Information

We collect the above-referenced categories of personal information from the following categories of sources:

• Directly from you: Much of the personal information we process is information that you or someone acting on your behalf directly provides to us. For example, you may provide us with Contact and Identification Information, Stay and Purchase Information, Payment Information, Demographic Information, and Health-related Information, when you create an account; book a reservation; complete surveys, sweepstakes, contests or promotional offers; contact customer service; or contact us via email, text, or chat, over the phone, in person, or through third parties.
• From your devices and our networks: We use cookies and related technologies to automatically collect personal information from and across your devices when you interact with the Website, Application, our emails, or other online content.
• From other businesses or individuals: We work with business and marketing partners and social media platforms that give us personal information about you that they have collected either directly or indirectly from you. We also use features that let your friends and family give us your personal information, for example when a family member or friend checks in on your behalf. We also may receive your personal information from (i) someone acting on your behalf, such as your travel agent or your employer (where your employer books travel for you), (ii) your travel provider, such as an airline, or (iii) your third party card or loyalty scheme provider.
• From social media: If you post to one of our pages on a social media site, we may receive Contact and Identification Information, Stay and Purchase Information, Internet and Network Activity, and any other personal information contained in your social media posts or profile.

5. How We Use Your Information

Subject to applicable laws, we may collect, use, and disclose your personal information in order to:

• provide, charge for, and manage hotel accommodation and other goods and services;
• provide you with customer support and a better or more personalized level of service at Claremont Location as well as through the Website, Application, frequent guest program (e.g., World of Claremont®), third party applications, products or services, or through products or services Claremont develops in the future;
• allow us to evaluate, analyze, and improve the functionality of our Website, Applications, or goods and services;
• facilitate concierge services on your behalf, e.g., restaurant, attraction and transportation transactions;
• administer travel, or discount programs;
• administer contests, sweepstakes, or other promotions;
• fulfill contractual obligations to you, anyone involved in the process of making your travel arrangements (e.g., travel agents, group travel organizers, or your employer) and vendors (e.g., credit card companies, airline operators, and third party loyalty, travel, or discount programs);
• conduct market research, customer satisfaction and quality assurance surveys;
• conduct marketing and sales promotions and serve targeted advertising for products, services, events, or promotions you might be interested in. Where permitted by law, we may work with other companies to serve advertisements or marketing that we think you may find relevant and useful. This may include advertisements displayed on our own Website or Applications, contained in emails or other communications sent by us, or advertisements from us displayed on other companies' website. The advertisements you see may be based on information collected by us or third parties and/or may be based on your activities on our Website, Applications or third-party websites;
• provide for the safety and security of staff, guests and other visitors;
• prevent, detect, and investigate fraud, cyber incidents, or other illegal activity;
• communicate with you about our relationship, such as updates to this Policy or other important legal or business changes;
• administer general record keeping;
• meet legal and regulatory requirements;
• test and evaluate new products and services;
• process credit applications;
• fulfill other purposes as disclosed to you in accordance with applicable law or with your consent; and
• use certain pieces of personal information to verify your identity if you make requests regarding your personal information pursuant to this Policy.  The verification steps and the pieces of personal information that we request may vary depending on the sensitivity and nature of your request.

When we process your personal information as one of our guests or someone else with whom we do business, we do so in our legitimate interests (as detailed above), because of legal obligations we are subject to, or because the information is required to fulfil contractual obligations either to you, to anyone involved in making your travel arrangements (e.g., travel agents, group travel organizers, or your employer) and/or to vendors (e.g., credit card companies, airline operators, and third party loyalty, travel, or discount programs).

Claremont uses and retains your personal information for as long as is necessary to fulfil the purpose for which it is being processed, and in line with our legal and regulatory obligations and risk management guidelines.

6. Disclosures of your Personal Information

From time to time, we may disclose your personal information. We would always make that disclosure in accordance with applicable law. In some jurisdictions, data privacy laws may require us to obtain your consent before we transfer your information from your originating country to other countries. When you agree to this Policy, you are, to the extent required and permitted under your local law, granting your consent to the transfer of your personal information to such other countries for the purpose and to the extent stated in this section and as described in Section 5 above.

Circumstances where we might make such disclosure (in addition to those described in Section 5 above) include:

6.1 Our Agents, Service Providers, and Suppliers

Like most international hotels, we may outsource the processing of certain functions and/or information to third parties. When we do outsource the processing of your personal information to third parties or provide your personal information to third-party service providers, we oblige those third parties to protect your personal information in accordance with the terms and conditions of this Policy, with appropriate security measures.

6.2 Consumer Insights

Where we hold personal information about you, we may disclose this personal information to other companies that also hold information about you. These companies may combine the information in order to better understand your preferences and interests, thereby enabling them and us to serve you better. If your personal information is used for direct marketing purposes, you have the right to object to that by contacting us using the contact information provided under Section 14 below. Further information about how we conduct direct marketing may be found at Section 10 below.

6.3 Credit Authorization

When you request credit, your personal information will be used and disclosed to appropriate third parties in accordance with applicable laws for the purpose of determining whether to grant and maintain a line of credit to you.

6.4 Business Transfers

As we continue to develop our business, we may sell the hotel, or cease being the manager of the Claremont Hotel. In those circumstances, we may include the personal information collected about you, or control of that personal information, as a business asset in any such transfer.  Also, in the unlikely event that we, or substantially all of our assets, are acquired, personal information collected about you, or control of such information, may be one of the transferred assets.

6.5 Legal Requirements

We reserve the right to disclose any personal information we have concerning you if we are compelled to do so by a court of law or lawfully requested to do so by a governmental entity or if we determine it is necessary or desirable to comply with the law or to protect or defend our rights or property in accordance with applicable laws. We also reserve the right to retain personal information collected and to process such personal information to comply with accounting and tax rules and regulations and any specific record retention laws.

7. International Transfers of Personal Information

Like most international businesses, we have centralized certain aspects of our data processing activities in accordance with applicable laws, which, in many instances, will result in the transfer of your personal information from one country to another. Nevertheless, whenever your personal information is transferred to the Claremont Hotel, your personal information will be processed in accordance with the terms and conditions of this Policy and applicable laws.

8. Interacting with us online

If you interact with us online, you may wish to know the following:

8.1 You Can Browse Without Revealing Who You Are

You can always visit our website without logging in or otherwise revealing who you are.

8.2 Cookies and Related Technologies

We and other parties use cookies and related technologies on our website to allow us to evaluate and improve the functionality of our website.  These cookies and related technologies also allow us, advertising networks, social media companies, and other providers, to place advertisements and customized content.

8.3 Social Media

Our website may also contain plug-ins and other features that integrate third party social media platforms into our website. You will be able to activate them manually. If you do so, the third parties who operate these platforms may be able to identify you, they may be able to determine how you use this website and they may link and store this information with your social media profile. Please consult the data protection policies of these social media platforms to understand what they will be doing with your personal data. If you activate these plug-ins and other features, you will be doing so at your own risk.

8.4 Creating a User Profile

You can create a user profile on a the Claremont website to, among other things, facilitate your online transactions, and to tailor your experience on our website to your interests. This allows us to make more appropriate recommendations to you. We may use the information you provide in your user profile to populate other databases maintained by us and our service providers, as applicable. By creating a user profile, you are agreeing that we may use the personal information you provide for these purposes.

If you subsequently elect to remove your user profile, we reserve the right to use any personal information previously provided by you for inclusion in your user profile for record keeping and quality assurance purposes (unless we are required by law to delete or cease to process or use your personal information). Even if you choose not to create a user profile, you can still use our website to search for and purchase services.

8.5 Links to Other Websites

If you click on a link found on our website or on any other website, you should always look at the location bar within your browser to determine whether you have been linked to a different website. This Policy, and our responsibility, is limited to our own information collection practices. We are not responsible for, and cannot always ensure, the information collection practices or privacy policies of other website maintained by third parties or our service providers where you submit your personal information directly to such website. In addition, we cannot ensure the content of the website maintained by these third parties or our service providers, even if accessible using a link from our website. We urge you to read the privacy and security policies of any external website before providing any personal information while accessing those website.

8.6 Security

Because the security of your personal information is important to us, the personal information we collect from you online is stored by us and/or our service providers on databases protected through a combination of physical and electronic access controls, firewall technology and other reasonable security measures. Nevertheless, such security measures cannot prevent all loss, misuse or alteration of personal information and we are not responsible for any damages or liabilities relating to any such incidents to the fullest extent permitted by law. Where required under law, we will notify you of any such loss, misuse or alteration of personal information that may affect you so that you can take the appropriate actions for the due protection of your rights.

8.7 Minor Children

Our website do not sell products or services for purchase by children and we do not knowingly solicit or collect personal information from children. If you are under the age of 18 (or a minor in the jurisdiction in which you are accessing our website), you may only use our website with the involvement of a parent or guardian.

9. Applications

When you download or register to use one of our apps, you may submit personal information to us such as your name, address, email address, phone number, date of birth, username, password and other registration information, financial and credit card information, personal description and/or image.

Further, when you use our apps, we may collect certain information automatically, including technical information related to your mobile device, your device's unique identifier, your mobile network information, the type of mobile browser you use and information about the way you use the app.

Depending on the particular app you use and only after you have agreed to such collection, we may also collect information stored on your device, including contact information, friends lists, login information (where necessary to allow us to communicate with other apps at your request), photos, videos, location information or other digital content. Further details of the kinds of information we collect is set out in the privacy notice for each individual app.

10. Choice

You may always choose what personal information (if any) you wish to provide to us. However, if you choose not to provide certain details, some of your experiences with us may be affected (for example, we cannot take a reservation without a name).

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. We may also share your personal information with carefully-selected third parties, who may communicate directly with you. In some jurisdictions, data privacy laws may require us to obtain a separate consent before we do so. You can always choose whether or not to receive any or all of these communications by contacting us as described in Section 13 below or following the “unsubscribe” instructions contained in the communications.

11. Updating or Accessing Your Personal Information and Your other Privacy Rights

With some limited exceptions, you may access and update personal information held about you. If you want to inquire about any personal information we may have about you, you can do so by clicking here, or by sending us a written request by letter or email to the addresses set out in Section 14 below. Please be sure to include your full name, address and telephone number and a copy of a document evidencing your identity (such as an ID card or passport) so we can ascertain your identity and whether we have any personal information regarding you, or in case we need to contact you to obtain any additional information we may require to make that determination. Where you make more than one request in quick succession, we may respond to your subsequent request by referring to our earlier response and only identifying any items that have changed materially.

You may request that we correct, delete, and/or stop or restrict processing or using personal information that we hold about you by clicking here, or by sending a letter or email to the addresses set out in Section 14 below. If we agree that the personal information is incorrect, or that the processing should be stopped, we will delete or correct the personal information. If we do not agree that the personal information is incorrect we will tell you that we do not agree, explain our refusal to you and record the fact that you consider that personal information to be incorrect in the relevant file(s).

If you are unhappy with the way we have handled your request, you can escalate your concern to the Chief Privacy Officer by sending an email to privacy@Claremont.com.

12. Changes to this Policy

Just as our business changes constantly, this Policy may also change. To assist you, this Policy has an effective date set out at the end of this document.

13. Request for Access to Personal Information/Questions or Complaints

If you have any questions about this Policy, about the processing of your data described, or any concerns or complaints with regard to the administration of the Policy, or if you would like to submit a request (in the manner described in Section 11 above) to exercise your rights in relation to the personal information that we maintain about you, please click here or contact us by any of the following means:

• by calling the phone number located at Claremont.com;
• by mail at Claremont Hotels 1700 Collins Ave. Miami Beach, FL 33139, United States; or

While this Policy alone does not create contractual rights, Claremont has ensured compliance with some of its legal obligations in relation to personal information.   

All requests for access to your personal information must be submitted in writing by letter or email. We may respond to your request by letter, email, telephone or any other suitable method.

Effective Date: October 2021