Issued 1 January 2020
This California Consumer Privacy Statement supplements the Belmond Group Privacy Policy and Data Notice on Processing of Personal Data and applies solely to California consumers. This Statement does not apply to (i) Belmond personnel or job applicants or (ii) personnel working on behalf of Belmond’s business partners. This California Consumer Privacy Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”).
1. Notice of Collection and Use of Personal Information We may collect the following categories of personal information about you:
Purposes
Categories of Personal Information
Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services
Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information and Inferences
Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance
Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
Debugging to identify and repair errors that impair existing intended functionality
Undertaking internal research for technological development and demonstration
Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us
2. Our Prior Collection, Use and Disclosure of Personal Information
We may have collected and used your personal information, as described in section 1 above, during the 12-month period prior to the effective date of this California Consumer Privacy Statement. For the personal information collected during that timeframe, we describe below: (a) the categories of sources from which we may have obtained the personal information, (b) the categories of third parties with whom we may have shared the information, (c) the categories of personal information we may have sold, and (d) the categories of personal information we may have disclosed for a business purpose.
a. Sources of Personal Information We may have obtained personal information about you from various sources, as described below.
Categories of Sources of Data Collection
Directly from you, such as when you fill in a form on any of our websites, fill in a physical registration card, opt in to receive marketing from us or provide us information as described in our Privacy Policy
From your devices, such as when you visit a Belmond website
Others who stay at our properties or use our services, such as your family or friends, your employer, or our corporate customers
Our affiliates and subsidiaries
Vendors who provide services on our behalf
Our business partners such as travel agents and reservations management platforms
Social networks
Online advertising companies
b.Sharing of Personal Information We may have shared your personal information with certain categories of third parties, as described below.
Categories of Third Parties
Your employer or other of our corporate customers with whom you are associated
Vendors who provide services on our behalf, such as data analytics providers
Professional services organizations, such as auditors and law firms
Online advertising companies such as advertising networks
Government entities
c. Sale of Personal Information We do not sell your personal information in exchange for monetary compensation. We may allow certain third parties (such as certain advertising partners) to collect your personal information via automated technologies on Belmond websites in exchange for non-monetary consideration (such as an enhanced ability to serve you content and advertisements that may be of interest to you). You have the right to opt out of this disclosure of your information: Do Not Sell My Information During the 12-month period prior to the effective date of this California Consumer Privacy Statement, we may have sold the following categories of personal information:
3. California Consumer Privacy Rights You have certain choices regarding our use and disclosure of your personal information, as described below. Access: You may have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months. Deletion: You have the right to request that we delete certain personal information we have collected from you. Opt-Out of Sale: You have the right to opt-out of the sale of your personal information. Shine the Light Request: You also may have the right to request that we provide you with (1) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (2) the identity of those third parties.
How to Submit a Request:
Verifying Requests: To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you have an account with us, we may verify your identity by requiring you to sign in to your account. If you do not have an account with us and you request access to or deletion of your personal information, we may require you to provide any of the following: A. If you have never stayed with us, your email address (we may send a security code to your email account to further verify your identity); B. If you have previously made a booking with Belmond, we will ask for: 1. the name of the last Belmond hotel/train/cruise you made a booking with: 2. the date of your last stay/trip with Belmond: 3. the amount of your last bill on checkout (if your last Belmond booking was a hotel stay) / the amount you spent on-board (if your last Belmond booking was a train or cruise). Please note that if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. If you designate an authorized agent to make an access, deletion or opt-out of sale request on your behalf (1) we may require you to provide the authorized agent written permission to do so, and (2) for access and deletion requests, we may require you to verify your own identity directly with us (as described above). Additional Information: If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us.
We may from time to time make certain special offers available to those who have provided their Personal Information to us. If you would like to provide your Personal Information to us to participate in those special offers, please email CCPA@belmond.com .
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