This California Consumer Privacy Statement supplements the Belmond Group Privacy Policy and Data Notice on Processing of Personal Data (“Privacy Policy”) and applies solely to California consumers. This Statement does not apply to Belmond personnel or job applicants. This California Consumer Privacy Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act and its implementing regulations (the “CCPA”).

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 medical condition, disability, or citizenship 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.

Some of the categories of personal information listed above are considered sensitive personal information under the CCPA. We do not use or disclose sensitive personal information, as defined by the CCPA, for purposes other than those specified in the CCPA.

We may use the categories of personal information listed above for the business 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:

Business 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 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
Providing advertising and marketing services, except for cross-context behavioral advertising, to the consumer	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, nonpersonalized advertising shown as part of your current interaction with Belmond	Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information and Inferences
Helping to ensure security and integrity of Belmond systems and 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
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>/td>
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.” See Slide 1 for a screenshot of the table and the correct Column 2 language.

 

We may also use, sell, or share these categories of personal information for certain commercial purposes, as described in this table:

Commercial Purposes	Categories of Personal Information
Personalized marketing and advertising	Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information and Inferences
Enabling commercial transactions	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

In the preceding 12 months, we may have collected and used your personal information, as described in section 1 above. 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 or shared, 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. Disclosure of Personal Information

We may have disclosed your personal information for a business purpose 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 or Sharing of Personal Information

In the preceding 12 months, we may have sold (including for targeted adverting) or shared your personal information with certain categories of third parties, as described below.

Categories of Third Parties	Categories of Personal Information
Online advertising companies such as advertising networks	Identifiers; Commercial Information; Online Activity and Inferences
Social networks	Identifiers; Commercial Information; Online Activity and Inferences
Vendors who provide services on our behalf, such as data analytics providers	Identifiers; Commercial Information; Online Activity and Inferences

 

 

We do not have actual knowledge that we sell or share the personal information of minors under 16 years of age.

d. Retention of California Personal Information

We retain the personal information we collect for as long as reasonably necessary to accomplish the purposes described above as further described in our Privacy Policy.

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 categories and specific pieces of personal information we have collected, used, disclosed and sold or shared 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.
• Correction: You have the right to request we correct inaccurate personal information we maintain about you.
• Opt-Out of Sale or Sharing: You have the right to opt-out of the sale or sharing of your personal information.
• Nondiscrimination: If you choose to exercise any of your rights above, you have the right to not receive discriminatory treatment by us.

 

How to Submit a Request:

• To submit an access, correction or deletion request, click here or call us at 866-874-2654.
• To opt-out of the sale of your personal information, click here.

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, correction of, 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, correction 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, correction and deletion requests, we may require you to verify your own identity directly with us (as described above).

Additional Information:

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 dpo@belmond.com.