I. RESPONSIBLE PARTY
The entity responsible for the management of your Personal Information is Eden Roc LLLP, with the following address: 4525 COLLINS AVENUE MIAMI BEACH, FL 33140.
II. APPLICATION OF THIS POLICY
This Policy applies to personal information regarding guests and the other individuals with whom we do business or who visit us and to the use of that personal information in any form – whether oral, electronic or written. While this Policy is intended to describe the broadest range of our 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 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.
We do not gather information that could result in discrimination, such as race or ethnicity, health status, genetic information, religious, philosophical and moral beliefs, union membership, political affiliation, or sexual orientation (“Sensitive Personal Information”).
III. TYPES OF PERSONAL INFORMATION COLLECTED
The term “personal information” in this Policy refers to information which does or is capable of identifying you as an individual. The types of personal information that we might process (which may vary by jurisdiction based on applicable law) include: your name, gender, home and work contact details, business title, date and place of birth, nationality and passport and visa information; guest stay information, including the hotels where you have stayed, date of arrival and departure, goods and services purchased, special requests made, observations about your service preferences (including room and holiday preferences), telephone numbers dialed and faxes and telephone messages received; your credit card details, frequent guest program member information, online user account details, profile or password details and any frequent flyer or travel partner program affiliation; any information necessary to fulfill special requests (e.g., health conditions that require specific accommodation, purchase of goods and services); information you provide regarding your marketing preferences or in the course of participating in surveys, contests or promotional offers; information collected through the use of closed circuit television systems, card key and other security systems; contact and other relevant details concerning the employees of corporate accounts and vendors and other individuals with whom we do business (e.g., travel agents or meeting and event planners); and in limited cases, information relating to the credit of customers.
Most of the personal information we process is information that you or someone acting on your behalf knowingly provides to us. However, in some instances, we process personal information that we are able to infer about you based on other information you provide to us or on our interactions with you, or personal information about you that we receive from a third party.
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 countries. Those laws define “Sensitive Personal Information” to 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 of a trade union or professional association, physical or mental health or condition, genetic data, sexual life or judicial data (including information concerning the commission or alleged commission of a criminal offence). We only process “Sensitive Personal Information” in your jurisdiction if and to the extent permitted or required by applicable law.
IV. HOW WE USE PERSONAL INFORMATION
The personally identifiable information you provide to us for making a reservation is made available to the applicable hotel for the purpose of meeting your reservation request. If you cancel your reservation, the information is stored for recordkeeping purposes only and is not accessed again. After making a reservation or completing your stay at a Nobu Hotel Miami Beach, a division of Eden Roc, LLLP., also known as Eden Roc Miami Beach Resort, unless you tell us otherwise, the information you provide may be used by us for direct marketing of Nobu Hotel Miami Beach, a division of Eden Roc, LLLP., other Nobu Hotel Miami Beach, a division of Eden Roc, LLLP products or the products of select, reputable third parties with whom Nobu Hotel Miami Beach, a division of Eden Roc, LLLP., has a strategic marketing relationship because they offer products or services that we believe would of interest to you. Nobu Hotel Miami Beach, a division of Eden Roc, LLLP., may use the services of a third party mail house for the sole purpose of mailing materials.
In addition subject to applicable laws, we may collect, use and disclose relevant portions of your personal information in order to: provide and charge for the hotel accommodation and other goods and services you purchase; provide you with a better, more personalized level of service; Nobu Hotel Miami Beach, a division of Eden Roc, LLLP., frequent guest program; fulfill 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 other loyalty programs); conduct market research, customer satisfaction and quality assurance surveys, direct marketing and sales promotions; respond to requests for information and services; provide for the safety and security of staff, guests and other visitors; administer general record keeping; to be provided to third parties for the legitimate business purposes of those third parties; market research firms; meet legal and regulatory requirements.
We treat the information you provide to us as confidential information; it is, accordingly, subject to security procedures and strict corporate policies regarding protection and use of confidential information. Because laws applicable to personal information vary by country, our hotels or other business operations may put in place additional measures that vary depending on the applicable legal requirements. Information collected on the sites covered by this privacy statement, which are listed in the first paragraph, is generally processed and stored in the United States.
It is our intention to only send you email communications that will be useful to you and that you want to receive. When you make a reservation and provide your e-mail address, we will occasionally contact you via e-mail and provide information about special offers and promotions that may be of interest to you. These communications will relate to Nobu Hotel Miami Beach, a division of Eden Roc, LLLP., offers and/or the promotions of select, reputable third parties with whom Nobu Hotel Miami Beach, a division of Eden Roc, LLLP., has a strategic marketing relationship because they offer products or services that we believe would of interest to you.
As we continue to develop our business, we may sell hotels and other assets, or cease being the manager or franchisor of a hotel that is currently part of our portfolio. In those circumstances, we may include the personal information collected about you, or control of that personal information, as a business asset in any such transfer. Also, in the unlikely event that we, or substantially all of our assets, are acquired, personal information collected from you, or control of such information, may be one of the transferred assets.
Like most international hotel brands, we may outsource the processing of certain functions and/or information to third parties. We may also engage market research firms to assist us in contacting guests for the purpose of market research and quality assurance. When we do outsource the processing of your personal information to third parties or provide your personal information to third party service providers, we oblige those third parties to protect your personal information with appropriate security measures and prohibit them from using your personal information for their own purposes or from disclosing your personal information to others.
V. INFORMATION PROTECTION
We guarantee the protection of your Personal Information. It should also be noted that it is protected through administrative, technical and physical security means in order to prevent the loss, alteration, destruction, use, access or improper disclosure.
VI. INFORMATION WE COLLECT WHEN YOU VISIT US ONLINE
If you choose to obtain information or do business with us online by visiting www.nobuhotelmiamibeach.com or or other Nobu Hotel Miami Beach, a division of Eden Roc, LLLP. websites, you may wish to know the following: A) You can always visit our websites without revealing who you are or providing any personal information. B) When you visit our websites, we may collect usage information (i.e., the Internet Protocol address automatically assigned to your computer each time you browse the Internet, the date and time of your visit, the type of Internet browser you use and the URL of any other website that referred you to our website, and the pages you access and the amunt of time you spend on each page), but that information is not linked to you as an individual unless you create a user profile. We use this information to evaluate and improve the features, guest experience and functionality of our websites. C) We may use “cookie technology” on our websites to allow us to evaluate and improve the functionality of our websites. Cookies by themselves cannot be used to reveal your identity. They identify your browser, but not you, to our servers when you visit our websites. If you do not want to accept cookies, you can block them by adjusting the settings on your Internet browser. However, if you block them, you will not be able to use all of the features of our websites, including the customization features associated with creating a user profile. D) You may be able to user profile on www.edenrochotelmiami.com, among other things, facilitate your online transactions, to tailor your experience on our websites to your interests and make more appropriate recommendations to you. We may use the information you provide in your user profile to populate other databases maintained by us and our service providers, as applicable. By creating a user profile, you are agreeing that we may use the personal information you provide for these purposes. You can view, update or remove any personal information that you have provided to us for inclusion in your user profile by amending your user profile online or emailing email@example.com. If you subsequently elect to remove your user profile, we will have the right to use any personal information previously provided by you for inclusion in your user profile for record keeping and quality assurance purposes. Even if you choose not to create a user profile, you can still use our websites to search for and purchase services. E) If you visit www.nobuhotelmiamibeach.com and decide, for example, to make an airline reservation, rent a car, or apply for a job online, you will be seamlessly linked to websites maintained by third parties with whom we have contracted to provide those services. If you click on a link found on our websites or on any other website, you should always look at the location bar within your browser to determine whether you have been linked to a different website. This Policy, and our responsibility is limited to our own information collection practices. We are not responsible for, and cannot always ensure, the information collection practices or privacy policies of other websites maintained by third parties or our service providers where you submit your personal information directly to such websites. In addition, we cannot ensure the content of the websites maintained by these third parties or our service providers, even if accessible using a link from our websites. We urge you to read the privacy and security policies of any external sites before providing any personal information while accessing those sites.
VII. ARCO RIGHTS
You have the right to request the access to, rectify, cancel and oppose the management of your Personal Information (the “ARCO Rights”). Furthermore, you have the right to request the revocation of your given consent, as well as limit the use of your Personal Information.
In order to exercise your rights, we ask that you send an e-mail to firstname.lastname@example.org, so we can send you the appropriate request form, which you should complete and submit through the same electronic means from which you received it. You may also go through this procedure personally in our offices.
For security purposes and in compliance with the Law, it is mandatory that all request forms be accompanied by the information necessary for us to identify the applicant, and if applicable his or her legal representative. As a result, your request form should be accompanied with the following documents:
A. Request form fully completed and signed;
B. Copy of the holder’s identification;
C. In the case of legal representation, simple copy of the Public Grant that establishes his or her Power-of-Attorney, as well as a simple copy of his or her identification;
D. Address, phone number, and e-mail;
E. Whether or not the holder accepts to be notified via e-mail;
F. Clear and precise description of the Information related to the exercise of your ARCO rights;
G. If applicable, indicate which specific piece of information should be corrected and how it should be correctly read.
H. If applicable, expressly state to revoke the consent to the management of your Personal Information;
I. Any other piece of information that will allow us to properly identify your Personal Information.
Allow us to inform you that we keep a record of all the submitted requests. Furthermore, in case the request form should be found incomplete, we have the right to request the missing information from you.
The applicant guarantees that the given Personal Information is exact, complete and authentic. As a result, the applicant is responsible for any damage and/or harm caused by falsified information or identity impersonation.
Your request shall be processed in accordance with the manner and time established in the Law and its Regulation. We commit ourselves to give a response no later than 20 (twenty) business days after we have received your request form. The waiting period could be extended by another 20 (twenty) business days if and when it is justified and the holder is notified.
Upon request of access to your Personal Information, it shall be given digitally. Upon request of expressly requesting it, your Information will be sent in the form of copies to your indicated address.
You have the right to revoke your consent to the management of your Personal Information. The procedure, requirements, and contact information needed for you to revoke your consent shall be the same as the procedure needed to exercise your ARCO Rights established above.
If you have not expressed disapproval of the terms mentioned in the present Notice, it shall be understood as given consent to the management of your Information.
IX. SECURITY MEASURES
Security measures cannot prevent all loss, misuse or alteration of personal information and we are not responsible for any damages or liabilities relating to any such incidents to the fullest extent permitted by law.
X. MINOR CHILDREN
Our websites do not sell products or services for purchase by children. If you are under the age of 18 (or a minor in the jurisdiction in which you are accessing our websites), you may only use our websites with the involvement of a parent or guardian.
XI. NOTICE UPDATE
From time to time and in compliance with the Law, Nobu Hotel Miami Beach, a division of Eden Roc LLLP, may modify or update this Notice. In which case, you may check any updates through our website: www.nobuhotelmiamibeach.com.
XII. DIGITAL MEANS
We inform you that we do not collect Personal Information through our website. It should also be noted that when you visit our offices, you are being video-recorded by our security cameras.
XIII. QUESTIONS OR COMMENTS
In case of any questions or concerns about the Notice, the management of your Personal Information or your rights, please feel free to contact our Manager of the Protection of Personal Information send us an e-mail at email@example.com.
Last updated on: April, 2017.
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