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.

If you are a Californian resident, for more information about your privacy rights, please click here.

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. Updates to our Privacy Policy
11. California Consumer Privacy (California Residents only)
12. How to contact us

1. Data Controller

Belmond Management Limited (UK company number 1680876) is the data controller with respect to your personal data and is registered with the UK Information 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 by telephone conversations, face-to-face interactions such as at the reservation desk or during the check-in/check-out process, interactions with our concierge and customer service desks, during the use of our in-house services such as restaurants, bars, and housekeeping;
• 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:

• name, address, date of birth, email address, telephone number
• 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 a specific booking, 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. We use cookies to gather data about the visitors to our websites, to enable us to improve our websites and deliver a better and more personalised service.

Data we collect through such means may comprise the following:

• 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.

Please note that the Belmond website (www.belmond.com) uses YouTube API Services, in relation to the videos we showcase. By using the Belmond website, you agree to be bound by the YouTube Terms of Service applicable to the YouTube API Services. A copy of those YouTube Terms of Service is available at https://www.youtube.com/t/terms

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3. Use of personal data

We will only use your personal data for the purposes and legal bases set out below:

Purpose	Legal Basis
We will use your data on the date and time of interactions, originating IP addresses, geographic locations, types of browser and operating systems used, URLs of referring pages and language preferences to make improvements to our website and social media pages and ensure that content is presented effectively.	Legitimate interest in improving digital platforms.
We will use your name and contact details to send you direct marketing and produce other content in relation to our relevant products and services, or other products and services provided by us, our affiliates and carefully selected partners.	Your consent.
We will use your name, address, date of birth, email address, telephone number, details of your reservations and dining experiences, information we receive about you from any third parties to facilitate bookings, payment, and other administrative processes related to your stay and dining experience.	Legitimate interest in efficient service provision. It is necessary for us to process your personal data in order to perform our contract with you.
We will use your name, date and time of visit, and purchasing patterns to assess and understand general trends and patterns relating to our business.	Legitimate interest in business analysis and development.
We will use your name, address, date of birth, passport and visa data, travel history and details of joint travellers; dates of your stay or travel with us, information we receive about you from any third parties or from other members of the Belmond Group to ensure the safety and security of yourself and our guests and visitors.	Legitimate interests in ensuring the safety and security of our premises and occupants.
We will collect, use and store your name, address, date of birth, email address, telephone number, details of your reservations and dining experiences to manage general record keeping.	Legitimate interest in maintaining accurate records.
We will collect, use and store your date and time of visit, originating IP address, domain name, type of browser and operating system used, URL of the referring page, object requested, completion status of the request, geographic location, and language preferences to compile statistics to understand how our website, services, and restaurant are used, and to improve operations.	Your consent for the use of cookies. Legitimate interest in operational improvement and analytics.
We will collect, use and store your name, address, date of birth, email address, telephone number, details of your reservations and dining experiences, reviews and opinions about our restaurant, and information we receive about you from any third parties to provide personalized services and improve our products and services based on user preferences.	We have a legitimate interest in promoting our services to our customers.
We will collect, use and store your name, address, date of birth, email address, telephone number, details of your reservations and dining experiences 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.	Necessary for compliance with a legal obligation.

There are instances where we have a legitimate interest to use your data. Our legitimate interest will vary depending on what we are using your data for, and we explain above what the interest is and how it relates to the processing operations that we are carrying out. Where we process personal data on the basis of a legitimate interest, then – as required by data protection law – we have carried out a balancing test to document our interests, to consider what the impact of the processing will be on individuals and to determine whether individuals interests outweigh our interests in the processing taking place. You can obtain more information about this balancing test by using the contact details at the end of the notice.

We may also use your personal data to enhance your Belmond experience. We may use the information you provide us, including your preferences details, to offer you a personalised and unique experience. We sometimes analyse or anticipate aspects related to your preferences, interests, and behaviour to tailor our services (including our marketing communications) and better suit your needs. We do this based on our legitimate interests. We understand and respect that not everyone may want their data to be used this way. Therefore, you have the right to opt-out of this personalisation at any time.

You can opt-out of profiling by:

• Clicking unsubscribe in marketing communications;
• Emailing unsubscribe@belmond.com stating that you want to opt out of profiling;
• Contacting us using the contact details provided in Section 12 of this Privacy Policy.

Please note, once we receive your opt-out request we will action it as soon as possible but please allow up to 10 business days for your request to take effect.

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:

Personal Data Category	Category of Recipient	Why?
All categories of personal data may be transferred.	Other members of the Belmond Group (http://pdfs.belmond.com/Belmond-Group-Entities.pdf) or the LVMH Group (https://www.lvmh.com/houses/), or our affiliated companies, which may use this data	To offer personalised products and services tailored to you consistent with the purposes identified in this Privacy Policy
Name, contact details (e.g., email address, telephone number), address, date of birth, details of reservations and dining experiences, payment data, purchase or delivery of products or services, reviews and opinions about our brands, products, and services, Date and time of interactions, originating IP addresses, geographic locations, types of browser and operating systems used, URLs of referring pages, language preferences.	Third party service providers	We employ other companies and individuals to perform functions on our behalf. Examples include web hosting, payment processing, information technology systems, customer relationship management, booking and reservations management, marketing, auditing, administration
Name, contact details (e.g., email address, telephone number), address, date of birth, details of your reservations and dining experiences.	Reservation platforms (such as The Fork, OpenTable and ResDiary)	To provide reservation services and associated customer service.
Name, address, date of birth, email address, telephone number, details of your reservations, details of your dining experiences, passport and visa data, travel history, details of joint travellers, dates of your stay or travel with us, payment data, information we receive about you from any third parties, information related to specific bookings, travel dates, details of payments made, special requests, and personal preferences (e.g., food and beverage preferences, interests).	Third party providers of components of any package holiday, excursion, transfer, concierge arranged activity/experience or other service we arrange for you	In order to fulfil your order for services you have requested from us.
All categories of data may be relevant.	Our advisors and insurers ;	To respond in the event of a claim, dispute or where otherwise necessary.
All categories of data may be relevant.	Third party owners of a Belmond Property (where the Belmond Property you visit is operated, but not owned by the Belmond Group).	To facilitate your stay and provide security.
All categories of data may be relevant.	law enforcement or any other government official	We are required to do so by law or pursuant to legal process or to comply with any applicable rules or regulations, or in response to a legitimate request.
All categories of data may be relevant.	Prospective Buyer/Seller	In the event that the business is sold or integrated with another business, your details will be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business.

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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 unsubscribe@belmond.com to indicate you no longer wish to receive marketing communications, or (iii) writing to us at the relevant 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 data protection law in the EU or United Kingdom, 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 the Belmond Group Data Protection Officer by (i) email at dpo@belmond.com, or (ii) writing to us at the relevant address set out in 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.

Please be aware that unsubscribing from the Belmond Group marketing emails does not impact your sign ups made directly with select Belmond restaurants.

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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”) and the United Kingdom. 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 and outside the United Kingdom.

If you are located in the EEA or the United Kingdom, 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; or
• we have put in place appropriate safeguards in respect of the transfer, for example we have entered into EU standard contractual clauses and required additional safeguards with the recipient, or the recipient is a party to binding corporate rules approved by an EU or UK supervisory authority.

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.

For a more detailed breakdown, view Belmond's data retention policy

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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. 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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11. California Consumer Privacy (California Residents only)

Specific laws apply to the personal information of Californian residents. Please click here for further information.

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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 Belmond Group Data Protection Officer at dpo@belmond.com or write to us at:

Belmond Group Data Protection Officer
Belmond Management Limited
Wogan House, 99 Great Portland Street, London, W1W 7NY

From 1 January 2021, Belmond has an appointed Representative for data protection matters in the EU, as required under European data protection legislation. If you reside in the EU, you can also contact us by writing our EU Representative (and/or emailing the Belmond Group Data Protection Officer at dpo@belmond.com):

Belmond Group EU Representative
Belmond Italia S.p.A.
Via B. Cavalieri 4
20121 Milan
Italy

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 Information Commissioner’s Office which is the Supervisory Authority of Belmond Management Limited or the Supervisory Authority in your country of residence.

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Special Clauses for Russia

These special clauses apply in all cases where we process personal data of data subjects residing in Russia. These special clauses supersede all other provisions of this Privacy Policy.

Data Operator. Belmond Management Limited (registered address: Wogan House, 99 Great Portland Street, London, W1W 7NY) is the data operator of personal data originated from data subjects residing in Russia. This Privacy Policy constitutes the document determining the data operator’s policy about the processing of personal data on www.belmond.com/ru and in other cases described above.

Personal Data We Collect. When we receive personal data about you from third parties, we will ensure that we have an appropriate lawful basis and give you a notice about the data processing (where required by the applicable law) prior to process your data.

We may process special categories of personal data where you have given your written consent and in other cases prescribed by the applicable law.

Use of Personal Data. The first paragraph of Section 3 of this Privacy Policy will not apply to the processing of your personal data. We will process your personal data for the purpose of concluding a a contract (the Legal Notice or Belmond Hotel Consumer Booking Terms and Conditions, or others) at the initiative of the data subject or performing such contract concluded between Belmond Management Limited and you or a contract where you act as a beneficiary. We will provide you with information, products, or services that you request from us or which we feel may interest you on the basis of your prior consent.

You may contact us through web-forms on our websites. In such a case, you must submit only your own, accurate, and up-to-date personal data. We may process personal data that you submitted through the web-forms for the purpose of considering your inquiries and responding to them on the basis of your consent. By submitting an inquiry, you also express your consent that we may disclose your inquiry and all personal data therein to third parties according to Section 4 hereof (where appropriate) and assign the processing of such data to our data processors.

Our processing actions may include the following: collection, record, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (provision and access), depersonalization, blockage, deletion, and destruction of personal data.

We ensure recording, systemisation, accumulation, storage, clarification (update, change) and extraction of personal data of Russian Federation citizens with the use of databases located in the territory of the Russian Federation when collecting this personal data in any manner including via the Internet.

Sharing Personal Data. We may share your personal data with third parties as described in Section 4 above upon your consent or if we are required to do so by law.

Your Rights. You, as a data subject, have the following rights:

• Right to receive information about the processing of your personal data;
• Right to demand for clarifying, blocking, or destroying your personal data in cases where such data is incomplete, outdated, incorrect, illegally received, or such data is unnecessary for the declared processing purpose;
• Right to submit complaints about actions (omission) of the data operator to competent authorities and bring a legal action;
• Right to defend your rights and legitimate interests, including the compensation of damages and/or moral damage, in court or according to other procedures established by the applicable law;
• Other rights established by the applicable law.

Data Transfers. We may send your personal data to the territory of countries ensuring or not ensuring an adequate level of protection of data subjects’ rights. We may send your data to the territory of countries not ensuring an adequate level of protection of data subjects’ rights (e.g. the United States) only if it is necessary for the performance of a contract concluded between you and Belmond Management Limited (the Legal Notice or Belmond Hotel Consumer Booking Terms and Conditions, or others).

Information about Data Security Requirement Performed by Us. We take all necessary administrative, legal, and technical measures to protect your personal data against unlawful or accidental access, destruction, change, blockage, copy, provision, and distribution as well as against other unlawful actions in respect of personal data. We fulfil the following data security requirements to the protection of personal data processed via information systems depending on the security level of information systems chosen by us: ensure security of premises accommodating the personal data information systems equipment in a way preventing any person without appropriate access rights from uncontrolled intrusion or stay in these premises; ensure safety of all personal data media; adopt by the general manager’s decision a document determining list of employees whose work duties require access to the personal data processed in the information system; use information security tools, of which compliance with the requirements of the information security laws is duly assessed and confirmed, when such tools are necessary for the neutralization of actual risks; appoint an employee responsible for the security of the personal data in the information system or impose this responsibility on an appropriate division; ensure that all changes of access rights with regard to the personal data in the information system are automatically recorded in the electronic messages log; and provide access to the electronic messages log only to those employees or other authorized persons who need this access for the discharge of their work duties.

How Long We Keep Personal Data. Section 8 of the Privacy Policy does not apply. We only retain 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. We will destroy your personal data within 30 days after you recall your data processing consent unless we may continue the data processing on the ground of another lawful basis.

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Special Clauses for China

These special clauses apply in all cases where we process personal data of data subjects residing in China. These special clauses supersede relevant provisions of this Privacy Policy.

The "Belmond" brand is operated and distributed in China by Belmond Management Limited, registered address: Wogan House, 99 Great Portland Street, London, W1W 7NY ("Belmond" or “We/Our/Us”).  We have appointed Belmond (Shanghai) Management & Consultancy Co., Ltd as our representative in China for data protection purposes.

Sharing Personal Data
a) SHARING
We share your personal data as described below, including:
（1）with external parties in accordance with laws and regulations, or mandatory requirements of government authorities;
（2）with our affiliated companies or business partners: we may share information related to our consumers with our affiliates or our business partners, for example, for trend analysis;
(3）with service providers that perform services on our behalf, such as:

• Companies that send newsletters, marketing materials and promotional information;
• Companies responsible for customer care services;
• Companies responsible for website data statistical analysis and market research;
• Individuals, companies, associations or professionals who provide assistance or consulting services (lawyers, accountants and auditors);
• IT system maintenance companies and data processing companies.

We enter into written agreements with the above companies on the purpose, duration, method of processing, types of personal data, protection measures, rights and obligations of both parties and will supervise their personal data processing activities. The collected data may also be shared with independent third-party data controllers, such as:

• Companies that manage credit card payment services and tax-free services;
• Companies that provide components of any package holiday, excursion, transfer, concierge arranged activity/experience or other service we arrange for you;
• 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);
• Other members of the Belmond Group, or our affiliated companies, which may use this data to offer products and services to you, when you have given consent;

Third-party e-commerce platforms, reservations management platforms media platforms or social platforms according to the applicable channels.

b) PUBLIC DISCLOSURE
We will only publicly disclose your personal data under the following circumstances:

• With your consent; or
• When required by law, legal procedures, litigation, or compulsory government authorities.

Your Rights
Subject to the exceptions provided by laws and regulations, you have the right to:

• consult, duplicate, change, or delete your personal data;
• object to our use of your personal data, or request that we restrict the use of your personal data;
• request the transfer of personal data;
• withdraw any consent you have given; and
• Cancel your relevant account.

Data Transfers
We may provide your personal data to entities outside China, including Belmond Ltd. In the United Kingdom, the entities in which it has an interest of 25% or more, from time to time and in each case any train, hotel, cruise or property owned or controlled by any such entity, in each case from time to time , and to service providers that process personal data on our behalf. You may contact us at any time through the contact information below with respect to the names and contact information of these entities.

We will perform the necessary procedures in accordance with the law and take necessary measures to ensure that the recipient meets the standards of protection stipulated by applicable laws and regulations. If expressly required by applicable laws, we will perform security assessment, certification or enter into a standard contract for the cross-border transfer of personal data, and determine whether to continue cross-border transfer of your personal data and whether to apply desensitization technologies in accordance with applicable laws.

Contact us
If you have any questions about how we process your personal data, please contact us by the following manner:
Contact information of person in charge of personal data protection: dpo@belmond.com

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