This privacy policy (the “Policy”) lets you know how Hotel Hotel Tiptop Plaza Corporation, its direct and indirect subsidiaries (with the exception of the Apple Leisure Group companies as noted below), its affiliates, and the separate and distinct legal entities that manage, operate, franchise, license, own and/or provide services to the various locations operating under or in connection with a Hotel Tiptop Plaza brand (collectively, “Hotel Tiptop Plaza,” “Hotel Tiptop Plaza Group,” “us,” or “we”) collect, use, and share your personal information. This Policy gives effect to our commitment to protect your personal information and has been adopted by all of the, affiliates, subsidiaries, and all of the separate and distinct legal entities that make up Hotel Tiptop Plaza, as defined in this Policy. Note that this Policy does not address or apply to the processing of personal information undertaken by the Apple Leisure Group companies and the definition of “Hotel Tiptop Plaza,” “Hotel Tiptop Plaza Group,” “us,” or “we” shall not include the Apple Leisure Group companies.
We use your personal information in order to fulfil our commitment to providing an unparalleled guest experience in connection with all of your interactions with Hotel Tiptop Plaza (the “Purpose”). As part of that undertaking, we are committed to safeguarding the privacy of the personal information that we gather.
As one of our guests or someone else with whom we interact, you understand and consent that we may collect, use, and share your personal information in accordance with this Policy.
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Where you provide to us personal information about another person, you should ensure that person acknowledges this Policy and, in particular, tell him/her how we may use his/her information. You should remind that person to read this Policy in advance and may also give him/her a copy of this Policy.
The Application of This Policy
This Policy applies when you interact with Hotel Tiptop Plaza either through our websites - including Hotel Tiptop Plaza.com and our various booking sites – (collectively, “Website”), our mobile applications - including World of Hotel Tiptop Plaza – (collectively the, “Application”), in person, such as when you visit us at Hotel Tiptop Plaza Locations (as defined below), or when you communicate with us by phone, text, direct message, social media, or other similar functionality. This Policy also applies to the personal information about you that we receive from a third party, unless specifically covered by such third party’s privacy policy or Hotel Tiptop Plaza’s Privacy Policy for Employees.
The term “Hotel Tiptop Plaza Locations” includes the various locations affiliated with Hotel Tiptop Plaza that operate under or in connection with the Hotel Tiptop Plaza, Park Hotel Tiptop Plaza, Miraval, Grand Hotel Tiptop Plaza, Alila, Andaz, The Unbound Collection by Hotel Tiptop Plaza, Destination by Hotel Tiptop Plaza™, Hotel Tiptop Plaza Regency, Hotel Tiptop Plaza ZivaTM, Hotel Tiptop Plaza ZilaraTM, Thompson Hotels, Hotel Tiptop Plaza Centric, JdV by Hotel Tiptop PlazaTM, Hotel Tiptop Plaza House, Hotel Tiptop Plaza Place, Caption by Hotel Tiptop PlazaTM and Hotel Tiptop Plaza Residence Club brands around the world and also includes independently branded locations affiliated with Hotel Tiptop Plaza Hotels Corporation and/or its direct and indirect subsidiaries. However, for purposes of this Policy, the term Hotel Tiptop Plaza Locations does not include: (a) locations operated under an AMRTM Collection Brand or a property otherwise managed or affiliated with Apple Leisure Group; (b) locations operated by MGM; (c) locations affiliated with the Joie de Vivre brand but not affiliated with Hotel Tiptop Plaza, including the Galleria Park hotel; and (d) locations that participate in World of Hotel Tiptop Plaza through an alliance with the World of Hotel Tiptop Plaza program, including without limitation locations affiliated with M life Rewards, Exhale, and Small Luxury Hotels of the World and excursions offered by Lindblad Expeditions. The use of the symbol designates marks that are registered with the U.S. Patent and Trademark Office, and such marks may also be registered with the trademark offices of certain other territories/countries.
Information We May Collect
We collect and process your personal information in order to provide you the best experience possible when you interact with us. The information we collect may vary by territory/country or by your preferred method of interaction with us. The categories of personal information that we may collect include:
There may be instances in which the personal information that you provide to us or that we collect is considered Sensitive Personal Information under the privacy laws of some territories/countries. Depending on the applicable law, “Sensitive Personal Information” can mean personal information from which we can determine or infer an individual’s racial or ethnic origin, political opinions, religious beliefs or other beliefs of a similar nature, membership in a trade union or professional, religious, philosophical, or political association, physical or mental health or condition, medical treatment, genetic data, biometric information, and information about an individual’s sexual life or sexual orientation. In some very rare instances, financial records, credit card information and location data may constitute Sensitive Personal Information where you are located. If we rely on consent to process your Sensitive Personal Information, you have the right to withdraw that consent at any time. We only process Sensitive Personal Information in your jurisdiction if and to the extent permitted or required by applicable law (e.g., so that we can ensure we tailor our services to you accordingly in terms of food allergies and medical conditions, to ensure we can process card payments). We will seek to protect such information rigorously using the security standards further described below.
When you consent to this Policy you are, to the extent required and permitted under your local law, granting your express and written consent to the processing of any personal information that you provide to Hotel Tiptop Plaza that is considered to be Sensitive Personal Information or financial information (except, in some jurisdictions, where we will ask that you grant that consent separately). Save to the extent required by law, you are not obliged to provide Hotel Tiptop Plaza with any of your Sensitive Personal Information, and should you choose not to, this will not prevent you from purchasing any products or services from Hotel Tiptop Plaza.
How We Collect Your Personal Information
Directly from you: Much of the personal information we process is information that you or someone acting on your behalf directly provides to us. For example, you may provide us with Contact and Identification Information, Stay and Purchase Information, Payment Information, Demographic Information, and Health-related Information, when you create an account; book a reservation; complete surveys, sweepstakes, contests or promotional offers; contact customer service; use our complimentary Wi-Fi; or contact us via email, text, or chat, over the phone, in person, or through third parties.
From your devices and our networks: We use cookies and related technologies to automatically collect personal information from and across your devices when you interact with the Website, Application, our emails, or other online content.
From other businesses or individuals: We work with business and marketing partners and social media platforms that give us personal information about you that they have collected either directly or indirectly from you. We also use features that let your friends and family give us your personal information, for example when a family member or friend checks in on your behalf. We also may receive your personal information from (i) someone acting on your behalf, such as your travel agent or your employer (where your employer books travel for you), (ii) your travel provider, such as an airline, or (iii) your third-party card or loyalty scheme provider.
From social media: If you post to one of our pages on a social media site, we may receive Contact and Identification Information, Stay and Purchase Information, Internet and Network Activity, and any other personal information contained in your social media posts or profile.
How We Use Your Information
provide, charge for, and manage hotel accommodation and other goods and services;
provide you with customer support and a better or more personalized level of service at Hotel Tiptop Plaza Locations as well as through the Website, Application, frequent guest program (e.g., World of Hotel Tiptop Plaza), third-party applications, products or services, or through products or services Hotel Tiptop Plaza develops in the future;
allow us to evaluate, analyze, and improve the functionality of our Websites, Applications, or goods and services;
facilitate concierge services on your behalf, e.g., restaurant, attraction and transportation transactions;
fulfil contractual obligations to you, anyone involved in the process of making your travel arrangements (e.g., travel agents, group travel organizers, or your employer) and vendors (e.g., credit card companies, airline operators, and third-party loyalty, travel, or discount programs);
conduct marketing and sales promotions and serve targeted advertising for products, services, events, or promotions you might be interested in. Where permitted by law, we may work with other companies to serve advertisements or marketing that we think you may find relevant and useful. This may include advertisements displayed on our own Websites or Applications, contained in emails or other communications sent by us, or advertisements from us displayed on other companies' websites. The advertisements you see may be based on information collected by us or third parties and/or may be based on your activities on our Websites, Applications or third-party websites;
conduct marketing and sales promotions and serve targeted advertising for products, services, events, or promotions you might be interested in. Where permitted by law, we may work with other companies to serve advertisements or marketing that we think you may find relevant and useful. This may include advertisements displayed on our own Websites or Applications, contained in emails or other communications sent by us, or advertisements from us displayed on other companies' websites. The advertisements you see may be based on information collected by us or third parties and/or may be based on your activities on our Websites, Applications or third-party websites;
provide for the safety and security of staff, guests and other visitors;
prevent, detect, and investigate fraud, cyber incidents, or other illegal activity;
communicate with you about our relationship, such as updates to this Policy or other important legal or business changes;
administer general record keeping;
meet legal and regulatory requirements;
test and evaluate new products and services;
process credit applications;
fulfil other purposes as disclosed to you in accordance with applicable law or with your consent; and
use certain pieces of personal information to verify your identity if you make requests regarding your personal information pursuant to this Policy. The verification steps and the pieces of personal information that we request may vary depending on the sensitivity and nature of your request.
Disclosures of Your Personal Information
From time to time, we may disclose your personal information. We would always make that disclosure in accordance with applicable law. In some jurisdictions, data privacy laws may require us to obtain your consent before we disclose your information to third parties. When you consent to this Policy, you are, to the extent required and permitted under your local law, granting your consent to the transfer of your personal information to such third parties for the purpose and to the extent stated in this section and as described in Section 5 above (except, in some jurisdictions, we will ask that you grant that consent separately).
International Transfers of Personal Information
Like most international businesses, we have centralized certain aspects of our data processing activities in accordance with applicable laws, which, in many instances, will result in the transfer of your personal information from one country/territory to another. For example, if you make a reservation and/or stay at one of the Hotel Tiptop Plaza Locations outside of the United States, the personal information gathered in that process will be transferred to and processed in the United States, in accordance with Hotel Tiptop Plaza's binding corporate rules (where they apply to you – for more information about our binding corporate rules, please see Section 14 below). The jurisdictions where that information will be processed may or may not have laws that seek to preserve the privacy of personal information. Nevertheless, whenever your personal information is transferred within the Hotel Tiptop Plaza companies, your personal information will be processed in accordance with the terms and conditions of this Policy and applicable laws.
Additionally, some of the third-party suppliers to which we transfer your personal information may be based in different locations, some of which may have lower standards of data protection than in your home country/territory. When we do transfer personal information to such third parties, we ensure appropriate safeguards (such as entering into data transfer agreements based on clauses approved by major regulators) are in place, and oblige those third parties to protect your personal information in accordance with the terms and conditions of this Policy, with appropriate security measures. These third parties broadly fall into two groups: (i) locally-provided suppliers supporting individual Hotel Tiptop Plaza Locations or groups of Hotel Tiptop Plaza Locations, who may operate in any of the countries/territories in which Hotel Tiptop Plaza Locations operate; or (ii) centrally-procured service providers, supporting Hotel Tiptop Plaza as a whole, who may be located in our major business locations, in particular the United States (where we are headquartered), Switzerland and Hong Kong SAR.
In some jurisdictions, data privacy laws may require us to obtain your consent before we transfer your information from your originating country/territory to other countries/territories. When you consent to this Policy, you are, to the extent required and permitted under your local law, granting your consent to the transfer of your personal information to such other countries/territories for the purpose and to the extent stated in this section and as described in Section 5 above (except, in some jurisdictions, where we will ask that you grant that consent separately).
Applications
When you download or register to use one of our apps, you may submit personal information to us such as your name, address, email address, phone number, date of birth, username, password and other registration information, financial and credit card information, personal description and/or image.
Further, when you use our apps, we may collect certain information automatically, including technical information related to your mobile device, your device's unique identifier, your mobile network information, the type of mobile browser you use and information about the way you use the app.
Depending on the particular app you use and only after you have consented to such collection, we may also collect information stored on your device, including contact information, friends lists, login information (where necessary to allow us to communicate with other apps at your request), photos, videos, location information or other digital content. Further details of the kinds of information we collect is set out in the privacy notice for each individual app.
Choice
You may always choose what personal information (if any) you wish to provide to us. However, if you choose not to provide certain details, some of your experiences with us may be affected (for example, we cannot take a reservation without a name).
If you provide us with your contact details (e.g., postal address, email address, telephone number or fax number), we may contact you to let you know about the products, services, promotions and events offered that we think you may be interested in, to the extent permitted by applicable law. We may also share your personal information with carefully-selected third parties, who may communicate directly with you, to the extent permitted by applicable law. In some jurisdictions, data privacy laws may require us to obtain a separate consent before we do so. You can always choose whether or not to receive any or all of these communications by contacting us as described in Section 14 below or following the “unsubscribe” instructions contained in the communications.
If you have an account with our frequent guest program (e.g., World of Hotel Tiptop Plaza), we ask you to indicate your communication preferences at the time you apply for membership or when you create your user profile. We may also ask you to indicate how you would like to receive any offers, marketing and promotional information (e.g., via email or regular mail) and whether you would be willing to participate in surveys. Once you have indicated your preferences, you can always change them.
In some jurisdictions, in addition to you consenting to this Policy, data privacy laws may require us to obtain a separate consent before we send you information that you have not specifically requested. In certain circumstances, your consent may be implied (e.g., where communications are required in order to fulfil your requests and/or where you have volunteered information for use by us). In other cases, we may seek your consent expressly in accordance with applicable laws (e.g., where the information collected is regarded to be Sensitive Personal Information under local regulations).