Dorchester Collection

California Consumer Privacy Policy

 

Introduction

This CCPA Privacy Policy is provided for California residents pursuant to the California Consumer Privacy Act (“CCPA”). If you are a California resident (“you” or “your”), this CCPA Privacy Policy provides you with additional information about Dorchester Collection and its hotels’ (“the Hotel,” “we,” “us,” or “our”) online and offline practices regarding your Personal Information, along with your rights regarding your Personal Information.

If you are not a California resident, please refer instead to our general Privacy Policy which you can find here: https://www.dorchestercollection.com/en/privacy-policy/

This policy was last updated on 8 September 2020.

Types of Personal Information We Collect

“Personal Information” means any information about an individual, which can be used to identify that person. It does not include data where the identity has been removed (anonymous data).

We collect a variety of Personal Information about our guests, customers and visitors to our website. As our website is not intended for children, we do not knowingly collect Personal Information relating to children.

This Personal Information falls into these categories:

  • Identifiers includes title, gender, first name, maiden name, last name, marital status, date of birth, username or similar identifier and an encrypted version of your login/password. If you interact with us through social media, this may include your social media user name.
  • Personal Information includes billing address, delivery address, email address, telephone numbers, payment card and direct debit/bank account details, your username and password.
  • Protected Characteristics includes age, color, disability, gender identity/expression, marital status, medical condition, national origin, race, religion, sex/gender.
  • Commercial Information includes details about payments to and from you and other details of products and services you have purchased from us.
  • Internet or other electronic network information includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website, how you use our website, products and services, information we or others collect about you from cookies and similar tracking technologies, such as web beacons, pixels, and mobile identifiers, purchases or orders made by you.
  • Audio, Electronic, Thermal Information includes photos and videos.
  • Inferences drawn from any of the Personal Information listed above to create a profile or summary about you, i.e. your online profiled data, such as your interests, preferences, feedback and survey responses, as well as any data which we have added (for example, using analytics and profiling), and your preferences in receiving direct marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered Personal Information in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as Personal Information which will be used in accordance with this privacy policy.

We do not ordinarily collect Biometric information about you (this includes information about your health and genetic and biometric data), nor do we collect any information about criminal convictions and offences. The only exceptions to this are: (i) if you provide health data to us as part of a spa booking, we will use this to perform our contract with you, and we need your explicit consent to use your health data as part of that; or (ii) you have made the special category data obviously public.

Remember, if you choose not to share personal data with us, or refuse certain contact permissions, we might not be able to provide the products and services you’ve asked for.

How and why we use your Personal Information

We may use your Personal Information to operate, manage, and maintain our Hotel’s business, to provide our products and services, for management purpose, and to accomplish our business purposes and objectives.

Click here to see a table explaining how we use your Personal Information, the types of Personal Information that applies to and why it is we can do this. When we explain why, we will identify the relevant category from explaining the legal bases for using personal data above, and, where it’s based on being able to do so for our legitimate interests, we will highlight what that legitimate interest is.

We may process your Personal Information for more than one legal basis depending on how we are using it.

What Personal Information Have We Shared to Third Parties

We have shared Personal Information and may share your Personal Information with third parties for our operational business purposes or for monetary or other valuable consideration. Third parties include our suppliers and service providers, Dorchester Collection group and affiliates, auditors and professional advisors like bankers, lawyers, accountants and insurers, and government, regulators and law enforcement. We also share Personal Information with third parties connected to advertising, retargeting and analytics.

In the preceding 12 months, we shared the following Personal Information to third parties for our operational business purposes:

  • Identifiers, such as name, passport, visa or other government-issued identification data, and online identifiers.
  • Personal Information, as defined in California Code Section 1798.80(e), such as name, contact information, and financial information.
  • Commercial Information, such as transaction information, purchase history, financial details, payment methods, and membership or loyalty program data
  • Internet or other electronic network information, such as browsing history and interactions with our and other websites and computer systems.
  • Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

We have “sold” the below categories of Personal Information to third parties. For purposes of this Privacy Policy, “sold” or “sale” means the disclosure of Personal Information for monetary or other valuable consideration but does not include, for example, the transfer of Personal Information as an asset that is part of a merger, bankruptcy, or other disposition of all or any portion of our business.

  • Identifiers, such as name, and online identifies (such as Dorchester Collection Diamond Club member number).
  • Personal Information, as defined in California Code Section 1798.80(e), such as name, contact information, and financial information.
  • Commercial Information, such as transaction information, purchase history, methods, and membership or loyalty program data
  • Internet or other electronic network information, such as browsing history and interactions with our and other website.
  • Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

We have “sold” the above Personal Information to the following categories of third parties:

  • suppliers and service providers (such as outsourced service providers for administration and hotel management (e.g. booking and reservation systems, customer relationship management systems), technology and media services providers, payment processing and fraud prevention providers, fulfilment partners for the gift shop);
  • Dorchester Collection group and affiliates;
  • auditors and professional advisers like bankers, lawyers, accountants and insurers; and
  • government, regulators and law enforcement.

As our website is not intended for children, we do not knowingly collect or “sell” Personal Information relating to minors under the age of 16.

Your Rights Under the CCPA

If you are a California resident, you have the following rights:

  • Right to Know about Personal Information, Collected, Disclosed, or Sold.
  • Right to Request that we disclose what Personal Information we collect, use, disclose, and sells, including:
    o    The categories of Personal Information that we collected of you,
    o    The categories of sources from which the Personal Information is collected,
    o    The business or commercial purpose for collecting or selling Personal Information,
    o    The categories of third parties with whom we share Personal Information,
    o    The specific pieces of Personal Information we have collected about you,
    o    The categories of Personal Information that we sold about you and the categories of third parties to whom we sold such Personal Information
  • Right to Request Deletion of any Personal Information that we collected for you.
  • Right to Opt-Out of any and all future “sale” of Personal Information.
  • Right to be Free From Unlawful Discrimination because you exercised any of your rights under the CCPA.

To make a request for the disclosures or deletion describe above, please contact us via this form or call +1 (833) 345-0754. An authorized agent may also complete the foregoing forms or call the toll-free number on your behalf. We will respond to your request consistent with applicable law. This includes matching identifying information provided by you on the form or during our call to your personal information that we maintain. We will ask you for basic information such as whether you’re a California resident, the nature of your request, your first and last name, and email. You will not be charged a fee for the verification of your request to know or delete.

To exercise your right to opt-out by clicking Do Not Sell my Personal Information or by calling +1 (833) 345-0754

Financial Incentives

The CCPA allows businesses to offer consumers financial incentives for sharing person information. For example, a business can offer a rewards program or provide a premium service to guests as compensation for their Personal Information.

The Hotels are part of the Dorchester Collection and allows guests and consumers to sign up as members by providing their first and last name and their email address. By providing these pieces of personal information, guests and consumers will receive news and special offer notifications. You may opt-in to receiving news and special offer notifications by going to dorchestercollection.com.

Upon entering the website a pop-up will appear titled, “Be the First to Know” or you may click on the mail icon on the top right hand corner of the screen. You must then provide your first and last name and email address.

If you choose to participate in any of the financial incentives offered by the Hotel, you have the right to withdraw from the financial incentive at any time. You may submit a request to withdraw from the financial incentive at any time by completing this form or by calling +1 (833) 345-0754.

If you have any questions about this California Consumer Privacy Policy, please do not hesitate to email us at [email protected] or send a letter addressed to: Privacy Manager, The Beverly Hills Hotel, 9641 Sunset Boulevard, Beverly Hills, CA, 90210 or Privacy Manager, Hotel Bel-Air, 701 Stone Canyon Road Los Angeles, CA, 90077.