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
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:
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:
5. How We Use Your Information
Subject to applicable laws, we may collect, use, and disclose your personal information in order to:
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
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.
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.
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.
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:
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