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 personal data that:

• is provided to us when you stay or travel with us (or make enquiries to stay or travel with us) either by you or by a third party through whom you have made an enquiry or booking; and
• we collect from you when you visit any of Belmond’s websites or which we obtain from any communications with you.

The following sections of this Privacy Policy describe the types of personal data we collect, how and for what purposes we use that personal data, with whom we share it, and the choices and rights available to you regarding our use of your personal data. We also describe the measures we take to protect the security of the personal data 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. Data Controller
2. Personal data we collect
3. Use of personal data
4. Sharing personal data
5. Your rights
6. Data transfers
7. How we protect your personal data
8. How long we keep personal data for
9. Links to other websites
10. Cookies
11. Updates to our Privacy Policy
12. How to contact us

1. Data Controller

Belmond Management Limited (company number 1680876) is the Belmond Group’s data controller and is registered with the Data Commissioner's Office with reference number Z1894972.

2. Personal data we collect

2.1 Personal data 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:

• filling in a form on any of our websites;
• filling in a physical registration card;
• opting in to receive marketing information with us;
• creating an on-line account with us and managing your preferences;
• contacting us by telephone or face to face (e.g. in the context of making a reservation);
• sending us a letter, e-mail or social media message;
• subscribing to receive a service from us (e.g. a newsletter, blog or by following us on social media);
• requesting promotional information from us (e.g. information about any of our goods or services including Belmond gift cards);
• participating in a survey, competition or prize draw; or
• contributing content to us (e.g. for display on a Belmond blog).

The types of information we may obtain include:

• passport and visa data, payment data, travel history and details of joint travellers;
• dates of your stay or travel with us and associated charges;
• purchase or delivery of products or services;
• reviews and opinions about our brands, products and services;
• information we receive about you from any third parties through whom you have booked your arrangements; and
• information we receive about you from other members of the Belmond Group (which may include information relating to travel dates, details of payments made to us, special requests and other information relating to your personal preferences (e.g. food and beverage preferences and interests).

‘Special category’ personal data

We do not collect data which is, by its nature, particularly sensitive (e.g. genetic data, biometric data, data revealing racial or ethnic origin, political opinions, sex life, sexual orientation, religion or other beliefs, data concerning health, criminal background or trade union membership) unless it is volunteered by you.

We may use certain sensitive (or “special category”) personal data where you have given your explicit consent to us doing so, to better serve and meet your needs. Such sensitive data is only shared with other members of the Belmond Group or our third party service providers acting as data processors (e.g. excursion providers, restaurants, transport providers) for the purpose of providing the services you request and will not be shared or used by us for any other purposes.

Examples of sensitive personal data we may collect and process include:

• food allergies;
• dietary requirements which may imply or suggest your religion, health or other sensitive personal data;
• mobility requirements;
• disabilities; and
• medical conditions.

2.2 Personal data we collect automatically

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

• date and time;
• originating IP address;
• domain name;
• type of browser and operating system used (if provided by the browser);
• URL of the referring page (if provided by the browser);
• object requested;
• completion status of the request;
• geographic location; or
• language preferences.

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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3. Use of personal data

As a provider of luxury hospitality experiences worldwide, Belmond has a legitimate business interest in operating and improving its business and the services it offers. Belmond therefore uses and processes your personal data to:

• help us create content that is relevant to our visitors;
• make improvements to our websites and social media pages and ensure that content on these is presented in the most effective manner for you;
• provide you with information, products or services that you request from us or which we feel may interest you;
• facilitate bookings, payment and other administrative processes related to your stay or travel;
• assess and help us understand general trends and patterns relating to our business;
• provide for the safety and security of our guests and visitors;
• manage general record keeping;
• enable us to compile anonymous, aggregated statistics that allow us to understand how users use our websites and to help us improve the structure of our websites;
• enable you to make reservations, buy Belmond gift cards and payments;
• meet any legal and/or regulatory requirements;
• provide the products or services you request from us including providing personalised services; and
• improve our products and services and to ensure our products and services are of interest to you.

Even where Belmond has a legitimate interest in processing your personal data, it will not do so to the extent that processing would override your interests, rights and freedoms to protect your personal data.

We may also use your personal data to protect against and prevent fraud, claims, and other liabilities and to comply with or enforce applicable legal requirements, industry standards, and our policies and terms. We use personal data for these purposes when it is necessary to protect, exercise or defend our legal rights, or when we are required to do so by applicable law.

In the situations set out below, we will only process your personal data when you have given us your specific consent and you have the right to withdraw your consent at any time (see Your rights below):

• marketing and profiling purposes which are managed solely by Belmond Management Limited as data controller for the Belmond Group. Your decision to provide your data for such purposes is optional and will have no consequence on your ability to stay with us or benefit from the requested services;
• all purposes concerning your booking, your stay and to provide you with the services you have requested, which are managed by Belmond Management Limited and the Belmond property(ies) you visit as joint controllers. Your decision to provide personal data (including special category/sensitive personal data) to us is voluntary, however, if you do not provide such personal data you may no longer be able to benefit from our services.

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

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4. Sharing personal data

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

We may share your personal data with third parties as described below:

• other members of the Belmond Group, which may use this data to offer products and services to you consistent with the purposes identified in this Privacy Policy;
• third party service providers who have been appointed as data processors to perform functions and services on our behalf and who will be provided only with personal data necessary to perform the services on our behalf but are not authorised by us to use such data for any other purposes (e.g. providers of services in respect of web hosting, payment processing, information technology systems, customer relationship management, booking and reservations management, marketing, auditing, administration);
• third party providers of components of any package holiday, excursion, transfer, concierge arranged activity/experience or other service we arrange for you;
• to our advisors and insurers in the event of a claim, dispute or where otherwise necessary;
• where the Belmond Property you visit is operated, but not owned by the Belmond Group, the owner of that Belmond Property (and its advisors and representatives);
• if we are required to do so by law or pursuant to legal process or to comply with any applicable rules or regulations (including but not limited to the rules of the New York Stock Exchange), or in response to a request from a law enforcement authority or other government official; and
• we reserve the right to transfer personal data 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 data you have provided to us in a manner that is consistent with this Privacy Policy. Following such a sale or transfer, you may contact the entity to which we transferred your data with any inquiries concerning the processing of that data.

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5. Your rights

We will only send you marketing communications if you “opted in” to receiving such communications. You have the right to “opt out” of receiving marketing communications, whether by email or otherwise, at any time. You can do this by (i) clicking the unsubscribe link displayed in any of the marketing e-mails you receive, (ii) emailing privacy@belmond.com to indicate you no longer wish to receive marketing communications, or (iii) writing to us at the address set out in How to contact us below.

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 data with third parties for their marketing use.

If you are a “data subject” under applicable EU data protection law, you will have the following rights in relation to personal data that we hold about you:

• Right to Access - to request confirmation of whether we process personal data relating to you, and if so, to request a copy of that personal data;
• Right to Rectification - to request that we rectify or update any personal data that is inaccurate, incomplete or outdated;
• Right to Erasure - to request that we erase your personal data in certain circumstances, such as where we collected personal data on the basis of your consent and you withdraw your consent;
• Right to Restriction of Processing - to request that we restrict the use of your personal data in certain circumstances, such as while we consider another request that you have submitted, for example a request that we update your personal data;
• Right to Withdraw Consent - where you have given us consent to process your personal data, to withdraw your consent; and
• Right to Data Portability - to request that we provide a copy of your personal data to you in a structured, commonly used and machine readable format in certain circumstances.

To exercise your rights as set out above or to make a complaint or submit an inquiry about our privacy practices, please contact us at privacy@belmond.com. You can also contact our Data Protection Officer (see How to contact us below).

To help protect your privacy and maintain security, we may take steps to verify your identity before we can action your request.

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6. Data transfers

We may transfer to, and store the data we collect about you in, countries other than the country in which the data 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 data. When we transfer your data to other countries, we will protect the data as described in this Privacy Policy and comply with applicable legal requirements providing adequate protection for the transfer of data to countries outside the EEA.

If you are located in the EEA, we will only transfer your personal data if:

• the country to which the personal data will be transferred has been granted a European Commission adequacy decision;
• the recipient of the personal data is located in the US and has certified to the US-EU Privacy Shield Framework; or
• we have put in place appropriate safeguards in respect of the transfer, for example we have entered into EU standard contractual clauses with the recipient, or the recipient is a party to binding corporate rules.

You may request more information about the safeguards that we have put in place in respect of transfers of personal data by contacting us as described in How to contact us below.

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7. How we protect your personal data

We maintain administrative, technical and physical safeguards designed to protect the personal data you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. Service providers and contractors who might have access to your data in order to provide services on our behalf will be contractually obliged to keep such data 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 data, credit card or similar personal data in any e-mails you send us or our staff.

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8. How long we keep personal data for

Belmond only retains your personal data for as long as needed to fulfil the purposes for which it is collected, unless we are required or permitted by law to keep the personal data for longer.

Your personal data will be anonymised or deleted if your last interaction with Belmond was over 7 years ago. “Interaction with Belmond” includes for example visiting a Belmond Property or opening marketing communications from Belmond.

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9. 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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10. 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 data 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 data in a website visitor’s cookie with any other data about 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 data on users of the Site. The technologies utilized allow Adroll to collect this data 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 data on users of the Site. The technologies utilized allow AppNexus to collect this data 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 to collect this data entirely anonymously and allow us to deliver interest-based advertising. BidSwitch’s privacy statement can be found here http://www.iponweb.com/privacy-policy/
Bing	Microsoft collects anonymous information on users of the Site through to conversion to enable tracking of marketing.https://privacy.microsoft.com/en-gb/privacystatement/
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 at www.google.com/policies/technologies/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
HotJar	Hotjar uses cookies to process information including standard internet log information and details of the visitor’s behavioral patterns upon visiting our site. This is done to provide our users with a better experience, and to facilitate the use of certain functions. https://www.hotjar.com/legal/policies/privacy
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 their customer experience using analytical cookies. Privacy policy available at 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 https://www.qubit.com/legal/product-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 here.
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 at 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:

• by continuing to use the website you consent to their use; or
• 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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11. 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 personal data 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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12. 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 personal data we have about you or your preferences, or to exercise Your rights (as detailed above), please email our Data Protection Officer at dpo@belmond.com or write to us at:

Data Protection Officer
Belmond Management Limited
1st Floor Shackleton House
4 Battle Bridge Lane
London
SE1 2HP

In the unlikely event that you wish to lodge a complaint about our collection, transfer or processing of your personal data, you can lodge a complaint with the UK Data Commissioner’s Office which is the Supervisory Authority of Belmond Management Limited.

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