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California Consumer Privacy Statement

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:

  • Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, passport number, and other similar identifiers
  • Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, bank account number, credit card number, debit card number, and other financial information, medical information, and health insurance information
  • Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, ancestry, disability, citizenship status, and military and veteran status
  • Commercial Information: commercial information, including products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
  • Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
  • Geolocation Data
  • Sensory Information: audio, electronic, visual, and similar information
  • Employment Information: professional or employment-related information
  • Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

  • We may use the categories of personal information listed above for the purposes described in our Privacy Policy. In addition, we may use these categories of personal information for certain business purposes specified in the CCPA, as described in this table:

    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

    Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information and Inferences

    Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction

    Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information and Inferences

    Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity

    Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information and Inferences

    Debugging to identify and repair errors that impair existing intended functionality

    Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information and Inferences

    Undertaking internal research for technological development and demonstration

    Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information and Inferences

    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

    Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information and Inferences

    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

    Categories of Personal Information

    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

    Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information and Inferences

    From your devices, such as when you visit a Belmond website

    Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information and Inferences

    Others who stay at our properties or use our services, such as your family or friends, your employer, or our corporate customers

    Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information and Inferences

    Our affiliates and subsidiaries

    Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information and Inferences

    Vendors who provide services on our behalf

    Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information and Inferences

    Our business partners such as travel agents and reservations management platforms

    Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information and Inferences

    Social networks

    Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information and Inferences

    Online advertising companies

    Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information and Inferences

    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

    Categories of Personal Information

    Our affiliates and subsidiaries

    Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information and Inferences

    Your employer or other of our corporate customers with whom you are associated

    Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information and Inferences

    Vendors who provide services on our behalf, such as data analytics providers

    Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information and Inferences

    Professional services organizations, such as auditors and law firms

    Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information and Inferences

    Our business partners such as travel agents and reservations management platforms

    Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information and Inferences

    Online advertising companies such as advertising networks

    Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information and Inferences

    Social networks

    Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information and Inferences

    Government entities

    Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information and Inferences

    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:

  • Identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, and other similar identifiers
  • Commercial information, including products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
  • Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
  • Inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
  • We do not sell the personal information of those we know to be under 16 years of age without affirmative authorization if we have actual knowledge of the individual’s age.
  • Disclosure of Personal Information for a Business Purpose

  • We may have disclosed to third parties for a business purpose all of the categories of personal information about you listed in Section 1 above.

    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:

  • To submit an access or deletion request, click here or call us at 866-874-2654.
  • To submit a Shine the Light request, email us at dpo@belmond.com
  • To opt-out of the sale of your personal information, Do Not Sell My Information .

  • 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.

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