PRIVACY POLICY AND INFORMATION NOTICE ON PROCESSING OF PERSONAL DATA

Last updated 7 February 2017

Belmond Management Limited, together with our holding company(ies), affiliates, subsidiaries and the hotels, trains, cruises or other properties we own, operate or manage (“Properties”) (together, “Belmond”, “Belmond Group”, “we” or “our”), respect the privacy of every individual who visits our Properties and/or uses any of our websites. For a list of Properties belonging to the Belmond Group, please click here.

This Privacy Policy applies to information that (i) you provide to us when you stay or travel with us (or make enquiries to stay or travel with us); and (ii) we collect from you when you visit any of Belmond’s websites. The following sections of this Privacy Policy describe the types of information we collect, how and for what purposes we use that information, with whom we share it, and the choices and rights available to you regarding our use of your information. We also describe the measures we take to protect the security of the information we hold and how to contact us about our privacy practices, and to exercise your rights.

Click on one of the links below to jump to the listed section:

1. Information we collect
2. Use of information
3. Sharing information
4. Your rights
5. Data transfers
6. How we protect your information
7. How long we keep information for
8. Links to other websites
9. Cookies
10. Updates to our Privacy Policy
11. How to contact us

1. Information we collect
Information you provide on a voluntary basis

We will collect, store and process information about you if you voluntarily provide us with such information in connection with the following:

The types of information we may obtain include:

We do not collect “sensitive information” (e.g., information on racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) unless it is volunteered by you.

We may use medical or other sensitive data provided by you to better serve and meet your needs (but under no circumstances will we process any sensitive data for marketing and/or profiling purposes). Such sensitive information is only shared with other members of the Belmond Group (acting as joint controller with Belmond Management Limited for booking management purposes) or our third party service providers (acting as data processors) for the purpose of providing the services you request. By making such special requests or notifying us of such preferences, you agree to us sharing your information in this way.

Personal information we collect automatically

When you visit a Belmond website, we may also collect certain information through the use of “cookies” and other automated means. Cookies are small pieces of information that are stored by your browser on your computer's hard drive. Such information may comprise the following information:

To learn more about cookies, how they are used and how to exercise your choice with respect to their collection of information on this site, please click here.

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2. Use of information
Typically, we will use and process your information to:

The processing of your personal information for:

We may process your personal information by both automated and manual means. We may use your information in other ways for which we provide specific notice at the time of collection.

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3. Sharing information

We do not sell, otherwise disclose, or share information we collect and hold about you, except as described in this Privacy Policy.

We may share your information within the Belmond Group, which may use this information to offer products and services to you consistent with the purposes identified in this Privacy Policy. We may also share information with service providers who perform functions and services on our behalf. Such third parties will be appointed as data processors and will be provided only with information necessary to perform the services on our behalf but are not authorised to use such information for any other purposes.

We may disclose information about you if we are required to do so by law or pursuant to legal process, or in response to a request from law enforcement authorities or other government officials.

We reserve the right to transfer information about you in the event that we sell or transfer all or a portion of our business or assets, in accordance with applicable law. Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use information you have provided to us in a manner that is consistent with our Privacy Policy. Following such a sale or transfer, you may contact the entity to which we transferred your information with any inquiries concerning the processing of that information.

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4. Your rights

You have certain rights to the information we process about you as expressly provided for by applicable law. You may request access to the information we hold about you, update, amend or correct the information, and in some circumstances you may object to our use of your information.

You also have the right to request that we cease sending marketing communications, whether by email or otherwise, to you. You can do this by (i) checking the applicable box(es) on any form used to collect information from individuals, or (ii) clicking the unsubscribe link displayed in any of the marketing e-mails you receive, or (iii) otherwise requesting that we do not process your information for marketing purposes, or (iv) via the Belmond on-line e-mail preference centre.

Pursuant to California's "Shine the Light Act", California residents are permitted to request information about the manner in which we share certain categories of information with third parties for their marketing use

To exercise these rights or to make a complaint or submit an inquiry about our privacy practices, please contact us at privacy@belmond.com. You can also write to us at:

Central Marketing
Belmond Management Limited
1st Floor Shackleton House
4 Battle Bridge Lane
London
SE1 2HP

To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information. Please note that if you opt out as described above, we will not be able to remove your information from the databases of third parties with whom we have already shared your information, with your consent. You should contact such third parties to opt out directly.

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5. Data transfers

We may transfer to and store the information we collect about you in countries other than the country in which the information was originally collected, including the United States, Canada or other destinations outside the European Economic Area (“EEA”). Those countries may not have the same data protection laws as the country in which you provided the information. When we transfer your information to other countries, we will protect the information as described in this Privacy Policy and comply with applicable legal requirements providing adequate protection for the transfer of information to countries outside the EEA.

By submitting your information to us, you agree to this transfer, storing and processing.

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6. How we protect your information

We maintain administrative, technical and physical safeguards designed to protect the information you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. Services providers and contractors who might have access to your information in order to provide services on our behalf will be contractually obliged to keep such information in confidence, provide adequate data security measures, and may not use that data for any other purpose.

For your own protection, we encourage you not to include sensitive personal information, credit card or similar data in any e-mails you send us or our staff.

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7. How long we keep information for

Belmond only retains your information for as long as needed to fulfil the purposes for which it is collected, unless otherwise provided by law.

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8. Links to other websites

Our websites may provide links to other websites for your convenience and information. These websites operate independently from us. Linked websites may have their own privacy policies, which we strongly suggest you review. To the extent that any linked websites you visit are not owned or controlled by us, we are not responsible for the websites’ content, any use of the websites, or the privacy practices of the websites.

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9. Cookies

A “cookie” is an element of data that a website can send to your browser which may then be stored on your system. We use cookies to gather information about the visitors to our websites (as they enable us to improve our websites and deliver a better and more personalised service). We do not associate the information in a website visitor’s cookie with any other informationabout that visitor.

The cookies we use on our websites, where you have accepted their use, are:

Cookie Name
Function
ARPT
Ensures that the user stays on the same server throughout their visit, ensuring consistent functionality throughout a visit. This cookie is destroyed at the end of the user’s visit
JSESSIONID
Ensures that the user’s session is maintained and works in conjunction with ARRPT to ensure consistent functionality throughout a visit. This cookie is destroyed at the end of the user’s visit
sifrFetch
Allows use of flash to improve display of text (if the user's browser supports it). This cookie is destroyed at the end of the user’s visit
user_countrycode
lounge_user_countrycode
user_lang_pref

These three cookies allow us to keep track of the users' geographic location and language preferences in order to display them relevant targeted and localised content as applicable.
user_campaign
user_creative
user_placement
internal_user_campaign
internal_user_creative
internal_user_placement

These cookies allow us to identify which of our marketing campaigns or internal promotions a user has been directed from/measure the effectiveness of campaigns/promotions.
user_id
lounge_user_id

These cookies allow us to identify the user and customise their experience. They also allow us to pre-populate fields in tables with your data, assisting with form entry.



In addition, the following are the third party cookies in use, where you have accepted their use (which are each subject to their own privacy and cookie policies):

Third Party Cookie

Function

Adroll

Adroll collects anonymous information on users of the Site. The technologies utilized allow Adroll to collect this information entirely anonymously and allow us to deliver interest-based advertising. Adroll’s privacy policy can be found here https://www.adroll.com/about/privacy

AppNexus

AppNexus collects anonymous information on users of the Site. The technologies utilized allow AppNexus to collect this information entirely anonymously and allow us to deliver interest-based advertising. AppNexus’ privacy statement can be found here http://www.appnexus.com//platform-policy

BidSwitch

BidSwitch collects anonymous information on users of the Site. The technologies utilized allow BidSwitch to collect this information entirely anonymously and allow us to deliver interest-based advertising. BidSwitch’s privacy statement can be found here http://www.iponweb.com/privacy-policy/

DoubleClick Advertising

Allows us to monitor (using non-personally identifiable data) the number and type of relevant searches made for it on Google. Privacy policy available atwww.google.com/intl/en/privacy/ads/

Facebook Custom Audience

Allows Belmond to create an audience using data held by Facebook to deliver interst-based advertising https://www.facebook.com/policy.php

Facebook Like Button

Allows users to choose to show our websites on their Facebook site. Privacy policy available at https://www.facebook.com/policy.php

Google Adwords

Google Adwords collects anonymous information on users of the Site through to conversion to enable tracking of marketing. The technologies utilized allow Adwords to collect this information entirely anonymously. Privacy policy can be found here : http://www.google.com/intl/en/policies/privacy/ You can opt-out of Google's use of cookies by visiting the Ads Preferences Manager, or through the Network Advertising Initiative opt-out page.

Google Analytics

Monitors usage of site (using non-personally identifiable data). Privacy policy available at www.google.com/intl/en/analytics/privacyoverview.html You can opt-out of Google's use of cookies by visiting the Ads Preferences Manager, or through the Network Advertising Initiative opt-out page.

Google Dynamic Remarketing

The Belmond Group are using 'Remarketing' to advertise online. This means that third-party vendors, including Google, will show ads on sites across the Internet. Google will use cookies to serve ads based on past visits to this website. Privacy policy can be found here : http://www.google.com/intl/en/policies/privacy/

You can opt-out of Google's use of cookies by visiting the Ads Preferences Manager, or through the Network Advertising Initiative opt-out page.

Google +1 Button

Allows users to choose to show our websites on their Google + account. Privacy policy available at www.google.com/intl/en/+/policy/+1button.html

LiveRamp

LiveRamp allows Belmond with CRM Retargeting through the use of anonymous cookies.

http://liveramp.com/data-privacy-policy/

Maxymiser

Maxymiser cookies allow Belmond to discover how our websites are working and optimise thei customer experience using analytical cookies.

https://www.maxymiser.com/cookie-policy

MediaPlex

Enables the direct measurement of traffic and audience characteristics. Privacy policy available at mediaplex.com/legal/mojo-privacy-statement

Qubit

Qubit cookies collect non-personal information, for example to learn about the behaviour of visitors to our website and how they respond to our marketing communications. The more we learn, the better we are able to provide relevant and interesting content. Qubit provide a Global opt out function which you can use to switch off all Qubit cookies http://www.qubitproducts.com/about/privacy-policy

OwnerIQ

OwnerIQ collects anonymous information on users of the Site. The technologies utilized allow OwnerIQ to collect this information entirely anonymously and we will never be able to identify you individually based on this information that is collected. Privacy policy can be found here http://owneriq.com/privacy-policy

OpenX

OpenX collects anonymous information on users of the Site. The technologies utilized allow OpenX to collect this information entirely anonymously and allow Belmond to deliver interest-based advertising. OpenX ‘s privacy policy can be found here http://openx.com/legal/ad-exchange-privacy-principles/

Quantcast

Enables the direct-measurement of traffic and audience characteristics, using non-personally identifiable data. Privacy policy available at http://www.quantcast.com/privacy

Rocket Fuel

Enables the direct measurement of traffic and audience characteristics. Privacy policy available at http://rocketfuel.com/privacy-policy

Right Media

Right Media collects anonymous information on users of the Site. The technologies utilized allow Right Media to collect this information entirely anonymously and allow us to deliver interest-based advertising. More information about Right Media can be found here http://info.yahoo.com/privacy/us/biz/rightmedia/details.html

Scorecard Research Tracking

ShareThis also makes use of Scorecard Research tracking which set the UID and UIDR cookies. Control your preferences or opt-out of Scorecard Research.

ShareThis

We use ShareThis to provide buttons on all pages to help you share our content. ShareThis also makes use of Scorecard Research tracking which set the UID and UIDR cookies. For more information on how to opt-out of these cookies view the ShareThis privacy policy.

Sizmek

Sizmek collects anonymous information on users of the Site. The technologies utilized allow Adroll to collect this information entirely anonymously and allow us to deliver interest-based advertising. Adroll’s privacy policy can be found here

Sojern

Sojern cookies collect non-personal data about behavior and travel intent. Privacy policy can be found here http://www.sojern.com/privacy/

Twitter Advertising

Allows interest-based advertising. Privacy policy https://twitter.com/privacy

Yahoo Advertising and Campaign Tags

Allows us to monitor (using non-personally identifiable data) the number and type of relevant searches made for it on Yahoo. Privacy policy available at info.yahoo.com/privacy/us/yahoo/details.html

Yandex

Allows users to search for our websites in the Russian language. Privacy policy available at company.yandex.ru/legal/en/confidential/

We do not control the use of such third party technology and we are not responsible for any actions or policies of such third parties. When you access our websites you will receive a clear notice advising you that the website you are visiting intends to use cookies and that:

i. by continuing to use the website you consent to their use; or
ii. you must click an “I accept” box in order for cookies to be placed.

Unless you have adjusted your browser setting so that it will refuse cookies from our websites, our system will issue cookies. Most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. You can find out how to do this for your particular browser by clicking "help" on your browser's menu or by visiting www.allaboutcookies.org. Please note, however, that without cookies you may not be able to take full advantage of all our websites features.

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10. Updates to our Privacy Policy

This Privacy Policy may be updated periodically and without prior notice to you to reflect changes in our processing of your information and privacy practices. We will post a prominent notice on each of Belmond’s websites to notify you of any significant changes to our Privacy Policy and indicate at the top of the Privacy Policy when it was most recently updated.

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11. How to contact us

If you have any questions or comments about this Privacy Policy, the use of cookies, if you would like us to update information we have about you or your preferences, or to exercise your rights of access, rectification, blocking, or deletion, or to object to the processing of your information, please contact us by email at privacy@belmond.com or write to us at:

Central Marketing
Belmond Management Limited
1st Floor Shackleton House
4 Battle Bridge Lane
London
SE1 2HP

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