Blue Diamond Hotels and Resorts Inc. and on behalf of its brands (Royalton, Hideaway at Royalton, Royalton CHIC, Mystique, Planet Hollywood, Memories, Grand Memories, Sanctuary at Grand Memories, Starfish) and its subsidiaries (collectively “we”, “us” or “our”) are committed to protecting your privacy, and support a general policy of openness about how we collect, use and disclose your Personal Information (as defined below) in accordance with relevant data protection laws.
The purpose of this Privacy Policy is to inform you about our practices relating to the collection, use and disclosure of Personal Information that may be provided through access to or use of our websites, services or products or that may otherwise be collected by us. By using any of our websites, mobile applications or other digital platforms that link to this Privacy Policy (collectively “Websites”), you consent to the collection, use and disclosure of your Personal Information in accordance with this Privacy Policy.
This Privacy Policy also explains how you can contact us if you have a question about, want to access, make a change to, object to the processing of or delete any Personal Information that we may be holding about you. As one of our guests or someone else with whom we do business, you understand and agree that we collect, use and disclose your Personal Information in accordance with this Privacy Policy.
While this Privacy Policy is intended to describe the broadest range of our Personal Information processing activities globally, those processing activities may be more limited in some jurisdictions based on the restrictions of their laws. For example, the laws of a particular country may limit the types of Personal Information we can collect or the manner in which we process that Personal Information. In those instances, we adjust our internal policies and/or practices to reflect the requirements of local law.
Generally, we collect your Personal Information directly from you, whether over the telephone, in writing, or electronically, including through any of our Websites, online products or services that link to this Privacy Policy. We may also collect it from a third-party service provider (including, without limitation, your financial institution, or, where you use our mobile application, your mobile device manufacturer or mobile service provider), or someone acting on your behalf (like a travel agent, tour operator, group travel organizer, family member, friend or employer who books products or services for you). Unless and until we are advised otherwise, we will consider a third party booking on your behalf to have your authority to provide us with your Personal Information in the same manner as if you were providing that information yourself. In the case of Personal Information of minors or those incapable of providing consent on their own behalf, those consenting on their behalf must be parents, legal guardians or legal representatives, as appropriate. Parents, legal guardians or legal representatives shall exercise privacy and data protection rights on behalf of such individuals.
For the purpose of this Privacy Policy, “Personal Information” means any information that can reasonably be used to identify a person, directly or indirectly, but does not include anonymous information or information that relates to a group of people rather than individuals where the information does not otherwise contain identifying information. We may collect your Personal Information during your dealings with us or while you visit our Websites, or where necessary to provide you with the products and services we offer, for example when you request a quote, make a reservation, contact us by e-mail or phone, or subscribe to our updates or newsletters. The types of personal information that we may collect and process (which may vary by jurisdiction based on applicable law) include, but not limited to:
We may collect data that is sensitive such as ethnic background or origin, religion, past and current health, and will seek your consent under applicable law. This sensitive data will be treated accordingly.
The Personal Information we process is information that you or someone acting on your behalf knowingly provides to us or information that we receive from a third party. In case of Personal Information belonging to minors or mentally incapables under applicable law, we will seek consent of parents, legal guardians or legal representatives, as appropriate. Parents, legal guardians or legal representatives shall exercise data protection rights on behalf of such minors or mentally incapable people.
This Privacy Policy also applies to the Personal Information about you that we receive from a third party, in accordance with applicable laws, unless specifically covered by such third party’s privacy policy. In such case, any inquiries about the privacy practices of third parties should be directed to them. Any such third party is responsible for obtaining your consent for the collection, use and disclosure of your Personal Information by us as described in this Privacy Policy, and advising you of this Privacy Policy, including any amendments hereto.
We collect Personal Information about you only when you voluntarily provide it. 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).
The way we use your Personal Information may differ depending upon how you interact with us, and what services or products you request, and we provide. The sections below provide details on specific ways that we may use your Personal Information.
Subject to applicable laws, we may use your personal information in order to:
Except with your consent, we will not transfer or assign in any form your Personal Information to or with third parties. From time to time, we may disclose your Personal Information as set out below. We would always make that disclosure in accordance with applicable data protection laws. In some jurisdictions, data privacy laws may require us to obtain your consent before we transfer your information from your originating country to other countries. When you agree to this Privacy 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 for the purposes set out in this Privacy Policy and to the extent stated in this section and as described in Section 4“How We Use Your Personal Information” above. Circumstances where we might make such disclosure (in addition to those described in Section 4“How We Use Your Personal Information” above) include:
We may disclose and you authorize us to disclose your Personal Information with its affiliates and subsidiaries, for the business purposes described in this Privacy Policy.
We may share and you authorize us to share your Personal Information with third parties engaged to assist us in providing services to you or to carry out one or more of the purposes described above, including third party suppliers who offer their products or services through our Websites (such as ground transportation and excursion providers) and third parties or our affiliates who provide us with information technology, data processing, data storage and other services which assist us with delivering products and services to you. These third parties are prohibited from using your Personal Information for any purpose other than to provide this assistance and we 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 may not process or otherwise use your Personal Information, except in accordance with our Privacy Policy and in accordance with applicable law.
We reserve the right to disclose Personal Information to a third party if a law, regulation, search warrant, subpoena or court order legally requires or authorizes us to do so, or in the context of discovery procedures or if we determine it is necessary or desirable to comply with the law or to protect or defend our rights or property in accordance with applicable laws. We also reserve the right to retain Personal Information collected and to process such Personal Information to comply with accounting and tax rules and regulations and any specific record retention laws.
We reserve the right to disclose and/or transfer Personal Information to a third party in the event of a proposed or completed corporate reorganization and to a related party or third party in the event of a proposed or completed purchase, sale (including a liquidation, realization, foreclosure or repossession), lease, license, merger, amalgamation or any other type of acquisition, disposal, transfer, conveyance or financing, the taking of security on, or securitization of all or any portion of us or of any of the business or assets or shares of us or a division thereof in order for you to continue to receive the same products and services from such related party or third party in accordance with applicable laws.
We may also disclose aggregated and anonymized information, which no longer allows an individual to be directly or indirectly identified, for study or research purposes, for the production of statistics, and such other purposes as permitted by applicable law.
If you have subscribed to receive our and/or our affiliates promotional and marketing email communications, we may also use (but will not share) your Personal Information to send you relevant information by email based on your subscription preferences, including by means of direct marketing. With your prior consent, we may also share your Personal Information to our affiliates so that they can send you promotional materials directly by email.
You may unsubscribe at any time by clicking the unsubscribe link imbedded at the bottom of our email communications. Note, however, that our clients, regardless of their opt-in preferences, will continue to receive periodic emails that relate to their business relationship with us. You can also choose not to allow us to use your Personal Information for marketing purposes by contacting us as outlined below in Section 14 (see “Contacting Us”).
If you believe that any of the purposes of use described above do not originate from or are not necessary for your relationship with us or if you choose not to allow us to use your Personal Information for marketing purposes, you may request that we not process your Personal Information for those purposes by contacting us as outlined below (see “Contacting Us”).
When you visit our Websites, we or one of our third party service providers may place a text file called a “cookie” in the browser directory of your computer’s hard drive. A cookie is a small piece of information that a website can store on your web browser and later retrieve information. The cookie cannot be read by any website other than the one that placed the cookie. Some browsers can be set to reject all cookies. If you choose to modify your browser in this manner, some pages of this Website may not function properly.
Upon your activation, these third party service providers may use cookies on our behalf to collect and store Internet log information, such as what time the visits occurred, whether the visitor has been to this site before, and what site referred the visitor to the web page. Geographic data may also be determined by the IP Address of the visitor’s computer. If you activate such function, this information collected by the cookie may be transmitted to our third party service providers and may then be used to evaluate visitors’ behaviour and to generate statistical reports for the website activity on our Websites and may be used for marketing purposes.
We make commercially reasonable efforts to ensure that your Personal Information is protected against loss, theft and unauthorized access, communication, copying, use, or modification. This protection applies in relation to information stored in both electronic and hard copy form. Access to your Personal Information is restricted to selected employees or representatives on a “need to know” basis. We employ generally accepted information security techniques, such as firewalls, access control procedures and cryptography, to protect Personal Information against loss and unauthorized access.
In addition, we have implemented a comprehensive set of policies and practices to protect your Personal Information. These measures take into account the volume, sensitivity, intended use, and format of the information, and generally include the following:
A dedicated Privacy Officer responsible for monitoring our compliance with applicable privacy laws and regulations and responding to privacy inquiries and complaints.
Our Websites may offer links to other third party websites. You should be aware that operators of linked websites may also collect your Personal Information (including information generated through the use of cookies) when you link to their websites. We are not responsible for how such third parties collect, use or disclose your Personal Information, so it is important to familiarize yourself with their privacy policies before providing them with your Personal Information.
Personal information collected by us is retained for as long as it is reasonably required for the purposes for which it was collected, or as permitted or required by law
We operate and provide products and services to guests located in many different countries around the world. The global nature of our business means that your Personal Information may be transferred across national boundaries, including, potentially, to countries that do not require companies to look after your Personal Information in the way you have come to expect in your own country (or province of residence). Your Personal Information may be subject to the laws of such foreign jurisdiction and may be accessible without notice to you by the courts, law enforcement and national security authorities of such foreign jurisdiction. Where we transfer your Personal Information across national boundaries, we will protect your Personal Information by ensuring that those transfers are made in compliance with all relevant data protection laws.
The safety and security of your Personal Information also depends on you. While many of our services are publicly accessible, your account information, where applicable, and some of our services are accessible only through the use of an individual user ID and password. To protect the confidentiality of your Personal Information, you must keep any password associated with your use of our services confidential and not disclose it to any other person. Please advise us immediately if you believe that the confidentiality of any such password has been compromised or that it has been misused. Please note that we will never ask you to disclose your password in an unsolicited phone call or email.
We are obliged to keep your Personal Information accurate and up to date. You can help us maintain the accuracy of your Personal Information by notifying us of any changes to this information. You may also contact our Privacy Officer as indicated below to withdraw your consent for processing your Personal Information, to access, correct, update, delete or object to the processing of your Personal Information, as well as to withdraw your consent to our use and/or disclosure of your personal information at any time subject to limited exceptions under applicable laws, or contractual requirements, and reasonable notice..
A request to access, correct, update or delete your Personal Information must be made in writing providing details of the Personal Information being sought. Depending on your jurisdiction, a minimal fee may be charged and, if so, we will inform you about the total cost.
In certain circumstances, we may need to restrict your rights to safeguard the rights of others, the public interest (for example, the prevention or detection of crime) and our interests (for example, the maintenance of legal privilege).
If you have an account on our Websites, you can view, manage and modify your Personal Information and preferences on your own, and you can opt in or out of features like electronic communications about our promotional offers and special offers from our partners.
We reserve the right update or modify this Privacy Policy at any time without notice to reflect changes in legal or regulatory obligations or changes in the manner in which we deal with Personal Information, as required or permitted by applicable law, including by posting an updated version on this Website, at which time we will update the effective date of this Privacy Policy to alert you of a change. Each time you use products or services that link or otherwise refer to this Privacy Policy, the version of this Privacy Policy then posted will apply to that use, so you should check this Privacy Policy each time you use such products or services. This Privacy Policy posted at any time or from time to time via this Website shall be deemed to be the Privacy Policy then in effect.
This Privacy Policy is effective as of November 17, 2023.
If you have any questions about this Privacy Policy, about the processing of your Personal Information, or any concerns or complaints with regard to the administration of this Privacy Policy, or if you want to submit a written request concerning your Personal Information, then you may contact our Privacy Officer at via email at [email protected].
We may require you to confirm your identity (such as by providing government-issued identification) before processing any request in relation with your Personal Information.
