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Hilton Momentum

VIRGIN HOTELS PRIVACY NOTIFICATION

Effective Date: May 6, 2020

This Privacy Policy describes the privacy practices that Virgin Hotels, LLC (“Virgin Hotels” or “us” or “we”) follows when collecting and using information about you on our website (www.virginhotels.com), Virgin Hotels mobile applications, our WiFi network, various systems at our properties and restaurants, in-room systems, and any other channel or mobile feature that we operate (collectively, the “Site”). We ask that you please read this Privacy Policy before using the Site. It describes what information we gather from you and others who visit or use the Site, how we use that information, and what we do to protect it. When you access or use the Site, certain information, including your Personal Information, may be collected, transferred, processed, stored, and in certain circumstances, made available or disclosed as described in this Privacy Policy.

This Privacy Policy complies with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Privacy Policy. Capitalized terms used but not defined in this Privacy Policy have the definitions provided in our Terms & Condition (located at https://virginhotels.com/terms-and-conditions/). Provisions within the Terms & Conditions may affect this Privacy Policy with respect to your use of the Site so please review the Terms & Conditions prior to using the Site.

BY CREATING AN ACCOUNT ON OUR SITE OR OTHERWISE PROVIDING US WITH YOURS OR OTHERS’ PERSONAL INFORMATION, YOU EXPRESSLY CONSENT TO THESE INFORMATION HANDLING PRACTICES AND YOU ACKNOWLEDGE AND CONFIRM THAT YOU HAVE PERMISSION TO PROVIDE US WITH ALL PERSONAL INFORMATION PROVIDED. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY OR OUR TERMS & CONDITIONS, PLEASE DO NOT USE, OR REGISTER FOR AN ACCOUNT ON, THE SITE.

Table of Contents:

1) THE INFORMATION WE COLLECT

2) THIRD PARTY ANALYTICS PROVIDERS

3) EXTERNAL LINKS

4) HOW WE USE YOUR INFORMATION

5) OUR INFORMATION SHARING PRACTICES

6) YOUR CHOICE AND OPTIONS RELATING TO OUR COLLECTION

7) ACCESSING AND UPDATING YOUR PERSONAL INFORMATION

8) SAFETY AND INFORMATION SECURITY MEASURES

9) NOTICE TO USERS OUTSIDE THE UNITED STATES

10) CALIFORNIA SHINE THE LIGHT LAW

11) CALIFORNIA MINORS

12) CHANGES TO THIS PRIVACY POLICY

13) PRIVACY QUESTIONS AND CONTACT INFORMATION

1) THE INFORMATION WE COLLECT:

We collect data to provide the products and services you request on the Site, ease your navigation on the Site, communicate with you, and improve your experience using the Site. Some of this information is provided by you directly to us, such as when you create an account. Some of the information is collected through your interactions with the Site or third party booking engines, websites, and property management services. We collect such data using technologies like cookies and other tracking technologies, error reports, and usage data collected when you interact with our Site. Some of the information is collected from your use of, and interactions with, us and others on social media including, but not limited to, Facebook®, Instagram®, Twitter®, Linked®, and YouTube® (collectively “Social Media”).

The data we collect depends on the Site and features thereof that you use, and includes the following:

1.1 Personal Information:

When you visit the Site without creating an account, you can browse without submitting Personal Information about yourself. In general, we collect Personal Information that you submit to us in the process of creating or editing your account and user profile on the Site or that you submit to us voluntarily through your use of the Site. Information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household is “Personal Information.”

In particular, the Site has collected the following categories of Personal Information from users in the last twelve (12) months. We obtain these categories of Personal Information with the methods described in more detail below.

Category Examples Collected
A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. YES
B. Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Some Personal Information included in this category may overlap with other categories.

 YES
C. Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). YES
D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. YES
E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. NO
F. Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. YES
G. Geolocation data. Physical location or movements. YES
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. NO
I. Professional or employment-related information. Current or past job history or performance evaluations. NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. NO
K. Inferences drawn from other Personal Information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. YES

Personal Information does not include:

  • Publicly available information from government records.
  • De-identified or aggregated consumer information.
  • Information excluded from the CCPA’s scope including, without limitation:
    • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and
    • Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We may also collect Personal Information from third parties, such as airlines, Social Media, Payment Processors, product vendors, and other partners. Our collection of this information allows us to provide you with our products and services, establish, maintain and support your user account on the Site, and communicate with you in accordance with our Terms & Conditions.

1.2 Automatically Collected Usage and Device Information:

Similar to other websites, we use tracking technologies to automatically collect certain technical information from your web browser, mobile, or other device when you visit our Site. This data may include, but is not limited to, your IP address, browser type and language, referring/exit pages and URLs, other browser history, platform type, number of clicks, landing pages, the pages you requested and viewed, the amount of time spent on particular pages, and the date and time of your visits. Our collection of this data, described in more detail below, allows us to provide more personalized high-quality services to you and to track usage of the Site.

A.     Cookies:

We use cookies, among other things, to process the Personal Information mentioned above. Cookies are files that are stored on your computer’s hard drive and are accessed by our server when you visit the Site. We use cookies for the purposes set forth in this Privacy Policy and for the preservation of our legitimate interests and, where applicable, on the basis of your consent.

Types of Cookies:

There are two different types of cookies used:

  • Session Cookies. Also called transient cookies, are cookies that are temporarily stored in your browser for the duration of a browser session, and they typically will store information in the form of a session identification without further information personally identifying you.
  • Persistent Cookies. Also called permanent or stored cookies, are cookies that are stored on your hard drive until they expire (persistent cookies are set with expiration dates) or until you delete the cookie. Persistent cookies are used to collect identifying information, such as web surfing behavior or user preferences for a specific website.

We employ the following categories of Session Cookies and Persistent Cookies:

  • Required Cookies
  • Functionality Cookies
  • Targeting/Advertising Cookies

These cookies are a mixture of first party cookies, which we set ourselves, and third-party cookies, which are set by other websites.

Cookie Functions:

We use cookies across the Site to improve its performance and enhance your user experience. Cookies are used to provide the following functions:

  • Personalization. For example, your language preference is remembered.
  • Session Management. To ensure that your session is routed to the correct system for the duration of your visit.
  • Usage Tracking. We use cookies to provide analysis of our users’ on-going usage of the Site. This allows us to adapt our offerings according to our users’ interests and facilitates on-going improvements to the Site.
  • AB Testing/Multivariate Testing. We can display multiple versions of a page to a user to assess which generates the best user experience.
  • Advertising. We can display advertising content depending on location, language, and your past browsing history.

Required Cookies:

We use a number of cookies that are strictly necessary to allow you to access the Site, to move between pages, and to receive services that you have requested. The types of data collected may include:

  • session identifier
  • IP address, and information generated from anonymized IP addresses
  • a computer host name
  • geographic location
  • time of visit
  • webpage URL
  • referring website
  • security tokens (for authentication and information submission, like RFP forms)

The following is an example of a strictly necessary cookie that we use:

  • Authentication Cookies. These provide an authentication method for secure log-in.

Functionality Cookies:

We use functionality cookies to allow us to remember your preferences. For example, cookies save you the trouble of selecting your language or currency every time you access the Site, and they recall your customization preferences.

We utilize other cookies to analyze how our users use the Site and to monitor Site performance. This allows us to provide a high-quality experience by customizing our offering and quickly identifying and fixing any issues that arise. For example, we might use performance cookies to keep track of which pages are most popular, which method of linking between pages is most effective, and to determine why some pages are receiving error messages.

The following is an example of a functionality cookie that we use:

  • Google Analytics: Refer to Section 2 (Third Party Analytics Providers) for more details.
  • Targeting/Advertising Cookies:

We and our partners and advertisers use cookies to display advertisements that we believe are relevant to you and your interests. We allow certain third party advertisers and partners to collect information about your use of the Site through first and third-party cookies so that they may analyze this data in order to serve advertisements to you on other third-party websites. We also work with advertisers in order to display our advertisements on third party websites, based on cookies set on your visit to the Site. Advertising/targeting cookies may also be used to track your responses to particular advertisements, which helps advertisers ensure that you see the most relevant advertisements in future on third party websites.

The types of data used include online identifiers, including cookie identifiers, IP addresses and device identifiers, imprecise location data (based on your IP address) or precise location data (if you have set your system to allow transmission of geolocation information), and client identifiers.

Types of targeting enacted based on cookies include:

  • Demographics. Target advertisements based on how well products and services trend with users in certain locations, ages, genders, and device types.
  • In-market. Show advertisements to users who have been searching for products and like-services.
  • Custom intent audiences. Choose words or phrases related to the people that are most likely to engage with sites and make purchases by using “custom intent audiences.”
  • Similar audiences. Target users with interests related to those on remarketing lists.
  • Remarketing. Target users that have already interacted with our advertisements or the Site.

We do not control the information collected by such third party partners or advertiser in connection with the Site or the further use of information we may provide to them for the aforementioned services, and they do not process such data on our behalf. Only the data protection policies of those third parties as the respective controllers of such data will apply to their processing of such data.

Cookie Consent:

When you visit the Site, you are notified of the use of cookies for tracking and analysis and asked to provide your express consent.

You can prevent or restrict the storage of cookies on your hard disk by setting your browser not to accept cookies or to request your permission before setting cookies. Once cookies have been set, you can delete them at any time. Please refer to your browser’s operating instructions to find out how this works. If you do not accept cookies, this can lead to restrictions in the use of the Site.

Data Retention and Deletion:

Log files are deleted after 120 days. Session cookies expire and are deleted at the end of your browser session. Persistent cookies may be set to expire from 30 days to 1 year depending on the function of the cookie. After expiry of those periods information will be deleted or made anonymous.

B. Pixels (aka web beacons/web bugs/java script):

We may use pixels to automatically record certain technical information about your interactions when you visit the Site or otherwise engage with us, to help deliver cookies on our Site, or count users who have visited the Site. We may also include web beacons in our promotional e-mail messages or newsletters to determine whether you open or act on them for statistical purposes. “Pixels” are tiny graphics (about the size of a period at the end of a sentence) with unique identifiers used to track certain online actions, movements and related information of Site users. Unlike cookies, which are stored on a user’s computer hard drive, pixels are embedded invisibly on web pages or in HTML-based emails. The data we receive through pixels allows us to effectively promote the Site to various populations of users, and to optimize external advertisements about the Site that appear on third-party websites.

1.3 Information from Other Sources:

We may obtain both personal and non-personal information about you from business partners, contractors, suppliers, and other third parties and add it to your account information or other information we have collected. We, and the third parties we engage, may combine information we collect from you over time, and across the Site, with information obtained from other sources. This helps us improve the information’s overall accuracy and completeness, and also helps us better tailor our interactions with you.

1.4 Location Information:

We collect precise geolocation data from you or your device, as well as your address information, e.g., billing address, when you set up your account and order our services. We also collect and use information about your general location (e.g., your state of residence) and can infer your approximate location based on your IP address in order to track our general Site usage or to tailor any pertinent aspects of your user experience to the region where you are located.

1.5 User Contributions:

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Site or transmitted to other users of the Site or third parties, including, for example, third party websites and services like Social Media that are integrated into or linked to the Site (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. We cannot control the actions of other users of the Site or third parties with whom you may choose to share your User Contributions. Such third parties may have their own policies and terms that apply to your User Contributions, and we are not responsible for any third party’s policies or terms. We cannot and do not guarantee that unauthorized persons will not view your User Contributions.

1.6 Social Media:

If you interact with us or our other users regarding Virgin Hotels and its products and services on any Social Media: (a) the Personal Information that you submit by and through such Social Media can be read, collected and/or used by us (depending on your Social Media privacy settings) as described in this Privacy Policy, and (b) where Virgin Hotels responds to any interaction with you on Social Media, your account name/handle may be viewable by any and all members or users of Virgin Hotels’ Social Media accounts. We are not responsible for the Personal Information that you choose to submit or link on any Social Media. Social Media operates independently from Virgin Hotels, and we are not responsible for Social Media interfaces or privacy or security practices. We encourage you to review the privacy policies and settings of any Social Media with which you interact to help you understand their privacy practices. If you have questions about the security and privacy settings of any Social Media that you use, please refer to the applicable privacy notices or policies.

2) THIRD PARTY ANALYTICS PROVIDERS:

We also use Google Analytics and other third party analytics providers (“Analytics Providers”) to collect information about Site usage and the users of the Site. Analytics Providers use Cookies in order to collect demographic and interest-level information and usage information from users that visit the Site, including information about the pages where users enter and exit the Site and what pages users view on the Site, time spent, browser, operating system, and IP address. Cookies allow Analytics Providers to recognize a user when a user visits the Site and when the user visits other websites. Analytics Providers use the information they collect from the Site and other websites to share with us and other website operators’ information about users including age range, gender, geographic regions, general interests, and details about devices used to visit the Site and other websites and purchase items. For more information regarding Google’s use of cookies, and collection and use of information, see the Google Privacy Policy (available at https://policies.google.com/privacy?hl=en). If you would like to opt out of Google Analytics tracking, please visit the Google Analytics Opt-out Browser Add-on (available at https://tools.google.com/dlpage/gaoptout).

3) EXTERNAL LINKS:

The Site contains links to third party websites and services, including links to Social Media. We are not responsible for any of the content or features or functionality of other linked websites or services. We are also not responsible for the privacy practices and the terms and conditions of use for any external websites or services. The linked websites and services may collect Personal Information from you that is not subject to our control. The data collection practices of linked third party websites and services will be governed by that third party’s privacy policy and terms of use.

4)  HOW WE USE YOUR INFORMATION:

4.1 General:

We may use or disclose the Personal Information identified above for one or more of the following business purposes (“Business Purpose”):

  • To fulfill or meet the reason you provided the information (e.g., to help provide lodging and services to you).
  • To personalize and develop our Site and the services we provide to you, and improve our offerings.
  • To provide certain features or functionalities on the Site.
  • For marketing and promotions, including to check your eligibility for competitions and to contact you in the event that you win, and to administer our rewards program.
  • To create, maintain, customize, and secure your account with us.
  • To provide you with support, to communicate with you and respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To personalize your experience and to deliver content and product and service offerings, products, and services relevant to your interests, including offers and advertisements through third-party sites, and via email (with your consent, where required by law).
  • To help maintain the safety, security, and integrity of our Site, services, databases, other technology assets, and business.
  • For testing, research, analysis, and product development, including to develop and improve our Site and services.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • To prevent illegal activity, fraud, and abuse.
  • As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our users is among the assets transferred or liquidated.

4.2 Account-Related Emails:

When you create an account with us and provide us with your email we may, subject to applicable law, use your email address to send you service-related notices (including any notices required by law, in lieu of communication by postal mail), updates, news, and marketing messages. For example, when you register, you will receive a welcome email. If the Site or our services are temporarily unavailable, we may also send you an email.

Email communications you receive from us will generally provide an unsubscribe link or instructions allowing you to opt out of receiving future emails or to change your contact preferences. If you have an account with us, you can also change your contact preferences by updating your contact information within your account settings. Please remember that even if you opt out of receiving marketing e-mails, we may still send you important service information related to your account and the Site. If you correspond with us by email, we may retain the content of your email messages, your email address, and our responses.

4.3 Advertising:

We do not use the Personal Information of our users to display any targeted advertising on our website. We do use third party service providers to serve advertisements or collect data on our behalf across the internet and on this Site (“Advertisers”). Some of these Advertisers may collect your Personal Information about your Site visits and your interactions with our products and services to tailor marketing messages on other sites, or to trigger real-time interactions, customize the Site, or enhance your profile. Advertisers may use cookies, pixels and other technologies to collect your Personal Information, measure the effectiveness of their advertisements, and personalize the advertisements on the Site. Some of these Advertisers may collect your Personal Information that you share on the Site via a web form automatically and prior to your submission of the Personal Information (i.e., before you click, “Submit”). Advertisers may be able to use information from your Site visits to send marketing messages to you in a way that could personally identify you. The information collected by Advertisers may include your IP address, email addresses and other user and device level information. For example, when Advertisers send advertisements and links that appear on the Site directly to your browser, they automatically receive your IP address. Please keep in mind that your browser settings may not permit you to control Advertisers’ technologies, and this Privacy Policy does not apply to, and we cannot control the activities of, Advertisers. If you would like more information about Advertisers’ practices, please see http://optout.aboutads.info/#!/.

4.4 Non-Personally Identifiable Information:

We may use non-personally identifiable information, such as anonymized and/or aggregated website usage data, in any manner that does not identify individual users for the purpose of improving the operation and management of the Site, including to develop new features, functionality, and services, to conduct internal research, to better understand Site usage patterns, to resolve disputes, to troubleshoot problems, to fulfill user requests, or for security and compliance purposes. Any non-personally identifiable information that is combined with Personal Information will be treated by us as Personal Information.

4.5 Payment Processors:

If you purchase or pay for products or services via the Site, the transaction may be handled by our service providers or third party vendor(s) responsible for processing your payment (“Payment Processors”). These entities have their own privacy policies and those terms will apply to you. Please be sure to review them at the links provided during payment processing.

5) OUR INFORMATION SHARING PRACTICES:

When we disclose Personal Information for a Business Purpose, we enter into a contract that describes the purpose and requires the recipient to keep that Personal Information confidential and use only for performance of the contract, and not for any other purpose. We share or make your information available, including any Personal Information, in the circumstances described below.

5.1 Disclosures of Personal Information in the Last Twelve Months:

In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for a Business Purpose, as more fully described in Section 4:

  • Category A: Identifiers.
  • Category B: California Customer Records personal information categories.
  • Category C: Protected classification characteristics under California or federal law.
  • Category D: Commercial information.
  • Category E: Biometric information.
  • Category F: Internet or other similar network activity.
  • Category G: Geolocation data.
  • Category K: Inferences drawn from other personal information.

We disclose your Personal Information for a Business Purpose to the following categories of third parties:

  • Social Media.
  • Analytics Providers.
  • Property owners and management companies of our hotels who may use your personal information to fulfil your requests and communicate with you about services or resources that we offer.
  • Affiliated persons or third-party service providers assisting us in the operation, management, improvement, research and analysis of the Site. Affiliated persons or our third party service providers may augment, extend, and combine non-personally identifiable information with data from additional third party sources in order to assist us with the above. Use of information by affiliated persons and third party service providers will be subject to this Privacy Policy or an agreement that is at least as restrictive as this Privacy Policy.

5.2 Sales of Personal Information in the Last Twelve Months:

Under the CCPA, the sale of Personal Information means “selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s Personal Information by the business to another business or a third party for monetary or other valuable consideration.” (Cal. Civ. Code § 1798.140(t)(1)). We make your Personal Information available to third parties, subject to your right to opt-out. In the preceding twelve (12) months, we have made available the following categories of Personal Information:

  • Category A: Identifiers.
  • Category B: California Customer Records personal information categories.
  • Category C: Protected classification characteristics under California or federal law.
  • Category D: Commercial information.
  • Category E: Biometric information.
  • Category F: Internet or other similar network activity.
  • Category G: Geolocation data.
  • Category K: Inferences drawn from other personal information.

We make your Personal Information available to the following categories of third parties:

  • Social Media.
  • Analytics Providers.
  • Property owners and management companies of our hotels who may use your personal information to fulfil your requests and communicate with you about services or resources that we offer.
  • Affiliated persons or third-party service providers assisting us in the operation, management, improvement, research and analysis of the Site. Affiliated persons or our third party service providers may augment, extend, and combine non-personally identifiable information with data from additional third party sources in order to assist us with the above. Use of information by affiliated persons and third party service providers will be subject to this Privacy Policy or an agreement that is at least as restrictive as this Privacy Policy.

5.3 Legal Requirements:

We reserve the right to disclose all information collected via the Site, internally, to affiliates, or to third parties, for any lawful purpose or to prevent harm to us or others. For example, and without limitation, in our discretion, we may disclose information to government regulators, law enforcement authorities or alleged victims of identity theft. We will notify you in the event of a government or legal request for your information unless otherwise prohibited by law.

5.4 Organizational Transitions:

If we should ever transfer or restructure the operational ownership of the Site, such as through a merger with another entity or a reorganization of all or a part of our operational responsibilities or assets, we may disclose, transfer, assign our rights, and/or delegate our duties to your information without notice and consent, including to prospective or actual recipient or acquiring entities. Should this occur, we will require any third party receiving your Personal Information as described under this subsection to be contractually required to provide the same level of privacy compliance as provided by us under this Privacy Policy.

5.5 Disclaimer:

We cannot ensure that all of your Personal Information will be disclosed only in the ways described in this Privacy Policy. For example, third parties may unlawfully intercept or access transmissions or private communications, or users may abuse or misuse your Personal Information that they collect from the Site. Even with the most rigorous information security standards, no transmission of data over the internet can be 100% secure.

6) YOUR CHOICE AND OPTIONS RELATING TO OUR COLLECTION:

You can choose not to provide Personal Information. You may always decline to provide your Personal Information to us. Registering for an account is not required to access some of our online content. If you decide to register, you can choose to provide information that does not reasonably identify you to others by selecting a username which is not related to your actual name. You can also decline to provide any optional information in your account. If you choose not to provide certain Personal Information to us, some of your experiences may be affected (e.g., we cannot take a reservation without your name and contact information).

6.1 You May Decline Other Requests:

We use your Personal Information as needed for the purposes for which it was collected or where you have consented to our use of such information. If you do not wish to provide information to us or do not wish to consent to the uses described in this Privacy Policy, please do not use the Site, set up an account, or supply the requested information to us.

6.2 Right to Access Specific Information and Data Portability Right:

You may have the right under the CCPA to request that we disclose certain information to you about our collection and use of your Personal Information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of Personal Information that we have collected about you.
  • The categories of sources for the Personal Information that we have collected about you.
  • Our business or commercial purpose for collecting or making available that Personal Information.
  • The categories of third parties with whom we share that Personal Information.
  • The specific pieces of Personal Information that we have collected about you (also called a data portability request).
  • If we disclosed your Personal Information for a Business Purpose, the Business Purpose for which such Personal Information was disclosed, and the Personal Information categories that each category of recipient obtained.
  • If applicable, (1) the categories of your Personal Information that we have made available for valuable consideration; (2) the categories of third parties to whom such Personal Information was made available; and (3) the category or categories of Personal Information that we have made available to each category of third parties.

6.3 Right to Delete:

You may have the right under the CCPA to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) or vendor(s) to:

  • Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation or legal order.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

6.4 Right to Opt-Out:

If you are 16 years of age or older, you may have the right under the CCPA to direct us not to make your Personal Information available for valuable consideration at any time (the “right to opt-out”). We do not make available the Personal Information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in, may opt-out at any time.

To exercise the right to opt-out or right to opt-in, you (or your authorized representative) may submit a request to us by sending us an e-mail at privacy@virginhotels.com or by completing and submitting a web form located here: https://submit-irm.trustarc.com/services/validation/0b4720ee-c3a7-4f45-ae90-a94f8319b39d. Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize certain information sharing practices. However, you may change your mind and opt back in at any time by sending us an e-mail at privacy@virginhotels.com. We will only use Personal Information provided in an opt-out request to review and comply with the request.

6.5 Exercising Your Rights:

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by:

Calling us at: 1- 833-217-8626

Sending us an e-mail at privacy@virginhotels.com

Completing and submitting a web form located here: https://submit-irm.trustarc.com/services/validation/0b4720ee-c3a7-4f45-ae90-a94f8319b39d

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make such a request for access or data portability twice within a twelve (12) month period. The verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative, and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. We will deliver our written response electronically. Any disclosures we provide will only cover the twelve (12) month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

6.6 Non-Discrimination:

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

6.7 Online Tracking Choices:

Most web browsers are initially set up to accept Cookies, but you can reset your browser to refuse Cookies or to indicate when a Cookie is being sent. However, some features and services in the Site (particularly those that require sign-in) may not function properly if your Cookies are disabled. Similarly, if you choose to delete session objects from the Site, you may not be able to access and use all or part of the Site or benefit from some or all of the information or features and services offered.

Some web browsers incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have the user’s online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain information about that browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many website operations, including the Site, do not respond to DNT signals.

7) ACCESSING AND UPDATING YOUR PERSONAL INFORMATION:

We do not review for accuracy or update your information regularly, but encourage you to access, review and update your Personal Information at any time. To request a copy of your Personal Information and data or for assistance regarding canceling your account, or deleting your Personal Information, contact us at privacy@virginhotels.com or by calling 1- 833-217-8626. We will respond to your request as soon as reasonably possible after verifying your authority to make such requests. Your requests for Personal Information deletion are subject to Section 6 of this Privacy Policy above and we will delete your Personal Information within a reasonable time.

8)  SAFETY AND INFORMATION SECURITY MEASURES:

8.1 Security:

We use certain physical, managerial, and technical safeguards designed to preserve the security of your information that we maintain in connection with your use of the Site. For example, we encrypt all data with secure sockets layer (SSL) or similar technologies when we transmit your data. This, however, does not guarantee that your information may not be accessed, disclosed, altered, or destroyed by any breach of our physical, technical or managerial safeguards. In the event that any of your Personal Information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and will notify you, as appropriate, in accordance with pertinent laws and regulations.

8.2 Storage:

We or our third party hosting providers store Personal Information in operating environments that are safeguarded against public or unauthorized access and protected from internal access with physical and technical security measures. While these measures are helpful to safeguard your Personal Information after we receive it, no transmission of data over the internet is 100% secure.

9) NOTICE TO USERS OUTSIDE THE UNITED STATES:

Please be aware that we are headquartered in the United States. The Site is governed by United States law. If you are using any of our products or services from outside of the United States, your information may be transferred to, stored, and processed in the United States where our servers may be located. The United States might not offer the same level of privacy protection as the country where you reside or are a citizen. BY USING THE SITE, COMMUNICATING WITH US VIA MAIL, EMAIL OR TELEPHONE, OR OTHERWISE PROVIDING INFORMATION TO US, YOU CONSENT TO THE TRANSFER TO, AND PROCESSING OF, YOUR INFORMATION IN THE UNITED STATES.

10) CALIFORNIA SHINE THE LIGHT LAW:

California Civil Code § 1798.83 permits users who are California residents to obtain from us once a year, free of charge, a list of third parties to whom we have disclosed Personal Information (if any) for direct marketing purposes in the preceding calendar year. If you are a California resident and you wish to make such a request, please send an e-mail with “California Privacy Rights” in the subject line to privacy@virginhotels.com.

11) CALIFORNIA MINORS:

While the Site is not intended for anyone under the age of 18, if you are a California resident who is under age 18 and you are unable to remove publicly-available content that you have submitted to us, you may request removal by contacting us at: privacy@virginhotels.com. When requesting removal, you must specify the information you want removed and provide us with specific information, such as the URL for each page where the information was entered, so that we can find it. We are not required to remove any content or information that: (1) federal or state law requires us or a third party to maintain; (2) was not posted by you; (3) is anonymized so that you cannot be identified; (4) you do not follow our instructions for removing or requesting removal; or (5) you received compensation or other consideration for providing the content or information. Removal of your information from the Site not ensure complete or comprehensive removal of that information from our systems or the systems of our service providers. We are not required to delete information posted by you; our obligations under California law are satisfied so long as we anonymize the information or render it invisible to other users and the public.

12) CHANGES TO THIS PRIVACY POLICY:

Because our privacy practices and privacy law necessarily evolve over time, we reserve the right to revise this Privacy Policy from time to time in our sole discretion, upon notice to you such as by posting updated Privacy Policy on the Site, sending you an email to your account email, or by any other reasonable means. You should periodically review this Privacy Policy to ensure that you are familiar with the most current version. Your continued use of the Site after the Effective Date posted above will constitute your acceptance of the updated Privacy Policy.

13) PRIVACY QUESTIONS AND CONTACT INFORMATION:

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your information described in this Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 1- 833-217-8626

Web Form: https://submit-irm.trustarc.com/services/validation/0b4720ee-c3a7-4f45-ae90-a94f8319b39d

E-mail: privacy@virginhotels.com