Your Curated Journey Starts Here
THE PAVILIONS HOTELS & RESORTS LIMITED: PRIVACY
POLICY
We Are Committed to Protecting Your Privacy
The Pavilions Hotels & Resorts Limited, located at Suite 303, 3/F,
St. George’s Building, 2 Ice House Street Central, Hong Kong and its group
companies including but not limited to The Pavilions Hotels & Resorts, The
Pavilions Residences, The First Roma Hotels, The Toren Hotel (“Pavilions
Group”) (together referred to as “Pavilions Group”, “we”, “us”, “ours” or “ourselves”
below), have a strong commitment to provide quality service to our guests,
patrons and potential customers and are further committed to protecting your
privacy.
The processing of personal data of a data subject by the Pavilions Group
shall always be in line with the General Data Protection Regulation (GDPR), and
in accordance with the country-specific data protection regulations applicable
to the Pavilions Group.
To ensure you as data subject can make informed decisions and feel
confident about supplying personal data relating to you when purchasing our
products and using our services, we provide this privacy policy (“Privacy
Policy”) (together with our terms of use and any other documents referred to on
it) outlining the nature, scope, and purpose of the personal data Pavilions
Group collect, use and process. Furthermore, you, as data subject, are
informed of the rights which you are entitled. You must read to fully
understand all data protection measures adopted by the Pavilions Group.
By using our websites (including https://www.pavilionshotels.com and
https://www.pavilionsresidences.com) and/or using services provided by the
Pavilions Group, you will be regarded as having accepted the terms of this
Privacy Policy.
We respect your privacy and are committed to protecting it through our
compliance with this privacy policy (“Policy”). This Policy describes the types
of information we may collect from you or that you may provide (“Personal
Information”) on the pavilionshotels.com website (“Website” or
“Service”) and any of its related products and services (collectively,
“Services”), and our practices for collecting, using, maintaining, protecting,
and disclosing that Personal Information. It also describes the choices
available to you regarding our use of your Personal Information and how you can
access and update it.
This Policy is a legally binding agreement between you (“User”, “you” or
“your”) and The Pavilions Hotels & Resorts Limited (doing business as “The
Pavilions Group”, “we”, “us” or “our”). If you are entering into this agreement
on behalf of a business or other legal entity, you represent that you have the
authority to bind such entity to this agreement, in which case the terms
“User”, “you” or “your” shall refer to such entity. If you do not have such
authority, or if you do not agree with the terms of this agreement, you must
not accept this agreement and may not access and use the Website and Services.
By accessing and using the Website and Services, you acknowledge that you have
read, understood, and agree to be bound by the terms of this Policy. This
Policy does not apply to the practices of companies that we do not own or
control, or to individuals that we do not employ or manage.
TABLE OF
CONTENTS
1.
Automatic collection of information
2.
Collection of personal information
4.
Use and processing of collected information
9.
Data protection rights under the GDPR
11.
How to exercise your rights
12.
Cookies
13.
Data analytics
15.
Advertisements
17.
Email marketing
19.
Affiliate links
22. Data breach
25. Contacting us
AUTOMATIC
COLLECTION OF INFORMATION
When you open the Website, our servers automatically record information
that your browser sends. This data may include information such as your
device’s IP address, browser type, and version, operating system type and
version, language preferences or the webpage you were visiting before you came
to the Website and Services, pages of the Website and Services that you visit,
the time spent on those pages, information you search for on the Website,
access times and dates, and other statistics.
Information collected automatically is used only to identify potential
cases of abuse and establish statistical information regarding the usage and
traffic of the Website and Services. This statistical information is not
otherwise aggregated in such a way that would identify any particular User of
the system.
COLLECTION OF
PERSONAL INFORMATION
You can access and use the Website and Services without telling us who
you are or revealing any information by which someone could identify you as a
specific, identifiable individual. If, however, you wish to use some of the
features offered on the Website, you may be asked to provide certain Personal
Information (for example, your name and e-mail address).
We receive and store any information you knowingly provide to us when
you make a purchase, or fill any forms on the Website. When required, this
information may include the following:
·
Contact information (such as email address,
phone number, etc)
·
Basic personal information (such as name,
country of residence, etc)
·
Proof of identity (such as a photocopy of a
government ID)
·
Payment information (such as credit card
details, bank details, etc)
·
Geolocation data of your device (such as
latitude and longitude)
·
Information about other individuals (such as
your family members, friends, etc)
·
Any other materials you willingly submit to us
(such as articles, images, feedback, etc)
You can choose not to provide us with your Personal Information, but
then you may not be able to take advantage of some of the features on the
Website. Users who are uncertain about what information is mandatory are welcome
to contact us.
PRIVACY OF
CHILDREN
We do not knowingly collect any Personal Information from children under
the age of 13. If you are under the age of 13, please do not submit any
Personal Information through the Website and Services. If you have reason to
believe that a child under the age of 13 has provided Personal Information to
us through the Website and Services, please contact us to request that we
delete that child’s Personal Information from our Services.
We encourage parents and legal guardians to monitor their children’s
Internet usage and to help enforce this Policy by instructing their children
never to provide Personal Information through the Website and Services without
their permission. We also ask that all parents and legal guardians overseeing
the care of children take the necessary precautions to ensure that their
children are instructed to never give out Personal Information when online
without their permission.
USE AND
PROCESSING OF COLLECTED INFORMATION
We act as a data controller and a data processor in terms of the GDPR
when handling Personal Information, unless we have entered into a data
processing agreement with you in which case you would be the data controller
and we would be the data processor.
Our role may also differ depending on the specific situation involving
Personal Information. We act in the capacity of a data controller when we ask
you to submit your Personal Information that is necessary to ensure your access
and use of the Website and Services. In such instances, we are a data
controller because we determine the purposes and means of the processing of
Personal Information and we comply with data controllers’ obligations set forth
in the GDPR.
We act in the capacity of a data processor in situations when you submit
Personal Information through the Website and Services. We do not own, control,
or make decisions about the submitted Personal Information, and such Personal
Information is processed only in accordance with your instructions. In such
instances, the User providing Personal Information acts as a data controller in
terms of the GDPR.
In order to make the Website and Services available to you, or to meet a
legal obligation, we may need to collect and use certain Personal Information.
If you do not provide the information that we request, we may not be able to
provide you with the requested products or services. Any of the information we
collect from you may be used for the following purposes:
·
Fulfil and manage orders
·
Deliver products or services
·
Improve products and services
·
Send administrative information
·
Send marketing and promotional communications
·
Send product and service updates
·
Respond to inquiries and offer support
·
Request user feedback
·
Improve user experience
·
Post customer testimonials
·
Deliver targeted advertising
·
Administer prize draws and competitions
·
Enforce terms and conditions and policies
·
Protect from abuse and malicious users
·
Respond to legal requests and prevent harm
·
Run and operate the Website and Services
Processing your Personal Information depends on how you interact with
the Website and Services, where you are located in the world and if one of the
following applies: (i) you have given your consent for one or more specific
purposes; this, however, does not apply, whenever the processing of Personal
Information is subject to California Consumer Privacy Act or European data
protection law; (ii) provision of information is necessary for the performance
of an agreement with you and/or for any pre-contractual obligations thereof;
(iii) processing is necessary for compliance with a legal obligation to which
you are subject; (iv) processing is related to a task that is carried out in
the public interest or in the exercise of official authority vested in us; (v)
processing is necessary for the purposes of the legitimate interests pursued by
us or by a third party. We may also combine or aggregate some of your Personal
Information in order to better serve you and to improve and update our Website
and Services.
We rely on our own legitimate interests and personal information is
already publicly available as legal bases as defined in the GDPR upon which we
collect and process your Personal Information.
Note that under some legislations we may be allowed to process information
until you object to such processing by opting out, without having to rely on
consent or any other of the legal bases above. In any case, we will be happy to
clarify the specific legal basis that applies to the processing, and in
particular whether the provision of Personal Information is a statutory or
contractual requirement, or a requirement necessary to enter into a contract.
PAYMENT
PROCESSING
In case of Services requiring payment, you may need to provide your
credit card details or other payment account information, which will be used
solely for processing payments. We use third-party payment processors (“Payment
Processors”) to assist us in processing your payment information securely.
Payment Processors adhere to the latest security standards as managed by
the PCI Security Standards Council, which is a joint effort of brands like
Visa, MasterCard, American Express and Discover. Sensitive and private data
exchange happens over a SSL secured communication channel and is encrypted and
protected with digital signatures, and the Website and Services are also in
compliance with strict vulnerability standards in order to create as secure of
an environment as possible for Users. We will share payment data with the
Payment Processors only to the extent necessary for the purposes of processing
your payments, refunding such payments, and dealing with complaints and queries
related to such payments and refunds.
Please note that the Payment Processors may collect some Personal
Information from you, which allows them to process your payments (e.g., your
email address, address, credit card details, and bank account number) and
handle all the steps in the payment process through their systems, including
data collection and data processing. Where necessary for processing future or
recurring payments and subject to your prior consent, your financial
information will be stored in encrypted form on secure servers of our Payment
Processors. The Payment Processors’ use of your Personal Information is
governed by their respective privacy policies which may or may not contain
privacy protections as protective as this Policy. We suggest that you review
their respective privacy policies.
We may also ask you to permit us to collect data about you from
third-party providers to verify your identity, do a credit check and prevent
fraud or assess risk. This helps us ensure that you are using our Services
legally, that you are eligible for the Services you want to use, and to protect
your data and our Services from fraudsters who may put you and your money at
risk.
DISCLOSURE
OF INFORMATION
Depending on the requested Services or as necessary to complete any
transaction or provide any Service you have requested, we may share your
information with our trusted subsidiaries and joint venture partners,
affiliates, contracted companies, and service providers (collectively, “Service
Providers”) we rely upon to assist in the operation of the Website and Services
available to you and whose privacy policies are consistent with ours or who
agree to abide by our policies with respect to Personal Information. We will
not share any information with unaffiliated third parties.
Service Providers are not authorized to use or disclose your information
except as necessary to perform services on our behalf or comply with legal
requirements. Service Providers are given the information they need only in
order to perform their designated functions, and we do not authorize them to
use or disclose any of the provided information for their own marketing or
other purposes. We will share and disclose your information only with the
following categories of Service Providers:
·
Advertising networks
·
Affiliate programs
·
Cloud computing services
·
Communication and collaboration services
·
Data analytics services
·
Data storage services
·
Financial services
·
Government agencies
·
Order fulfilment services
·
Payment processors
·
Performance monitoring services
·
Product engineering and design services
·
Sales and marketing services
·
Social networks
·
User authentication services
·
Website hosting service providers
We may also disclose any Personal Information we collect, use or receive
if required or permitted by law, such as to comply with a subpoena or similar
legal process, and when we believe in good faith that disclosure is necessary
to protect our rights, protect your safety or the safety of others, investigate
fraud, or respond to a government request.
In the event we go through a business transition, such as a merger or
acquisition by another company, or sale of all or a portion of its assets, your
Personal Information will likely be among the assets transferred.
RETENTION
OF INFORMATION
We will retain and use your Personal Information for the period
necessary to comply with our legal obligations, to enforce our agreements,
resolve disputes, and unless a longer retention period is required or permitted
by law.
We may use any aggregated data derived from or incorporating your
Personal Information after you update or delete it, but not in a manner that
would identify you personally. Once the retention period expires, Personal
Information shall be deleted. Therefore, the right to access, the right to
erasure, the right to rectification, and the right to data portability cannot
be enforced after the expiration of the retention period.
TRANSFER OF
INFORMATION
Depending on your location, data transfers may involve transferring and
storing your information in a country other than your own. The transfer of your
Personal Information to countries outside the European Union will be made only
if you have explicitly consented to it or in the cases provided for by the GDPR
and will be processed in your interest.
You are entitled to learn about the legal basis of information transfers
to a country outside the European Union or to any international organization
governed by public international law or set up by two or more countries, such
as the UN, and about the security measures taken by us to safeguard your
information. If any such transfer takes place, you can find out more by
checking the relevant sections of this Policy or inquire with us using the
information provided in the contact section.
DATA
PROTECTION RIGHTS UNDER THE GDPR
If you are a resident of the European Economic Area (“EEA”), you have
certain data protection rights and we aim to take reasonable steps to allow you
to correct, amend, delete, or limit the use of your Personal Information. If
you wish to be informed what Personal Information, we hold about you and if you
want it to be removed from our systems, please contact us. In certain
circumstances, you have the following data protection rights:
(i) You have the right to withdraw consent where you have previously
given your consent to the processing of your Personal Information. To the
extent that the legal basis for our processing of your Personal Information is
consent, you have the right to withdraw that consent at any time. Withdrawal
will not affect the lawfulness of processing before the withdrawal.
(ii) You have the right to learn if your Personal Information is being
processed by us, obtain disclosure regarding certain aspects of the processing,
and obtain a copy of your Personal Information undergoing processing.
(iii) You have the right to verify the accuracy of your information and
ask for it to be updated or corrected. You also have the right to request us to
complete the Personal Information you believe is incomplete.
(iv) You have the right to object to the processing of your information
if the processing is carried out on a legal basis other than consent. Where
Personal Information is processed for the public interest, in the exercise of
an official authority vested in us, or for the purposes of the legitimate
interests pursued by us, you may object to such processing by providing a
ground related to your particular situation to justify the objection. You must
know that, however, should your Personal Information be processed for direct
marketing purposes, you can object to that processing at any time without
providing any justification. To learn whether we are processing Personal
Information for direct marketing purposes, you may refer to the relevant
sections of this Policy.
(v) You have the right, under certain circumstances, to restrict the
processing of your Personal Information. These circumstances include: the
accuracy of your Personal Information is contested by you and we must verify
its accuracy; the processing is unlawful, but you oppose the erasure of your
Personal Information and request the restriction of its use instead; we no
longer need your Personal Information for the purposes of processing, but you
require it to establish, exercise or defend your legal claims; you have
objected to processing pending the verification of whether our legitimate
grounds override your legitimate grounds. Where processing has been restricted,
such Personal Information will be marked accordingly and, with the exception of
storage, will be processed only with your consent or for the establishment, to
exercise or defense of legal claims, for the protection of the rights of
another natural, or legal person or for reasons of important public interest.
(vi) You have the right, under certain circumstances, to obtain the
erasure of your Personal Information from us. These circumstances include: the
Personal Information is no longer necessary in relation to the purposes for
which it was collected or otherwise processed; you withdraw consent to
consent-based processing; you object to the processing under certain rules of
applicable data protection law; the processing is for direct marketing
purposes; and the personal data have been unlawfully processed. However, there
are exclusions of the right to erasure such as where processing is necessary:
for exercising the right of freedom of expression and information; for
compliance with a legal obligation; or for the establishment, to exercise or
defense of legal claims.
(vii) You have the right to receive your Personal Information that you
have provided to us in a structured, commonly used, and machine-readable format
and, if technically feasible, to have it transmitted to another controller
without any hindrance from us, provided that such transmission does not
adversely affect the rights and freedoms of others.
(viii) You have the right to complain to a data protection authority
about our collection and use of your Personal Information. If you are not
satisfied with the outcome of your complaint directly with us, you have the
right to lodge a complaint with your local data protection authority. For more
information, please contact your local data protection authority in the EEA.
This provision is applicable provided that your Personal Information is
processed by automated means and that the processing is based on your consent,
on a contract which you are part of, or on pre-contractual obligations thereof.
CALIFORNIA
PRIVACY RIGHTS
Consumers residing in California are afforded certain additional rights
with respect to their Personal Information under the California Consumer
Privacy Act (“CCPA”). If you are a California resident, this section applies to
you.
In addition to the rights as explained in this Policy, California
residents who provide Personal Information as defined in the statute to obtain
Services for personal, family, or household use are entitled to request and
obtain from us, once a calendar year, information about the categories and
specific pieces of Personal Information we have collected and disclosed.
Furthermore, California residents have the right to request deletion of
their Personal Information or opt-out of the sale of their Personal Information
which may include selling, disclosing, or transferring Personal Information to
another business or a third party for monetary or other valuable consideration.
To do so, simply contact us. We will not discriminate against you if you
exercise your rights under the CCPA.
HOW TO
EXERCISE YOUR RIGHTS
Any requests to exercise your rights can be directed to us through the
contact details provided in this document. Please note that we may ask you to
verify your identity before responding to such requests. Your request must
provide sufficient information that allows us to verify that you are the person
you are claiming to be or that you are the authorized representative of such
person. If we receive your request from an authorized representative, we may
request evidence that you have provided such an authorized representative with
power of attorney or that the authorized representative otherwise has valid
written authority to submit requests on your behalf.
You must include sufficient details to allow us to properly understand
the request and respond to it. We cannot respond to your request or provide you
with Personal Information unless we first verify your identity or authority to
make such a request and confirm that the Personal Information relates to you.
COOKIES
Our Website and Services use “cookies” to help personalize your online
experience. A cookie is a text file that is placed on your hard disk by a web
page server. Cookies cannot be used to run programs or deliver viruses to your
computer. Cookies are uniquely assigned to you, and can only be read by a web
server in the domain that issued the cookie to you. If you choose to decline
cookies, you may not be able to fully experience the features of the Website
and Services.
We may use cookies to collect, store, and track information for security
and personalization, to operate the Website and Services, and for statistical
purposes. Please note that you have the ability to accept or decline cookies.
Most web browsers automatically accept cookies by default, but you can modify
your browser settings to decline cookies if you prefer.
DATA
ANALYTICS
Our Website and Services may use third-party analytics tools that use
cookies, web beacons, or other similar information-gathering technologies to
collect standard internet activity and usage information. The information
gathered is used to compile statistical reports on User activity such as how
often Users visit our Website and Services, what pages they visit and for how
long, etc. We use the information obtained from these analytics tools to
monitor the performance and improve our Website and Services. We do not use
third-party analytics tools to track or to collect any personally identifiable
information of our Users and we will not associate any information gathered
from the statistical reports with any individual User.
DO NOT
TRACK SIGNALS
Some browsers incorporate a Do Not Track feature that signals to
websites you visit that you do not want to have your online activity tracked.
Tracking is not the same as using or collecting information in connection with
a website. For these purposes, tracking refers to collecting personally
identifiable information from consumers who use or visit a website or online
service as they move across different websites over time. How browsers
communicate the Do Not Track signal is not yet uniform. As a result, the
Website and Services are not yet set up to interpret or respond to Do Not Track
signals communicated by your browser. Even so, as described in more detail
throughout this Policy, we limit our use and collection of your Personal
Information. For a description of Do Not Track protocols for browsers and
mobile devices or to learn more about the choices available to you, visit internetcookies.com
ADVERTISEMENTS
We may permit certain third-party companies to help us tailor
advertising that we think may be of interest to Users and to collect and use
other data about User activities on the Website. These companies may deliver
ads that might place cookies and otherwise track User behaviour.
SOCIAL
MEDIA FEATURES
Our Website and Services may include social media features, such as the
Facebook and Twitter buttons, Share This buttons, etc (collectively, “Social
Media Features”). These Social Media Features may collect your IP address, what
page you are visiting on our Website and Services, and may set a cookie to
enable Social Media Features to function properly. Social Media Features are
hosted either by their respective providers or directly on our Website and
Services. Your interactions with these Social Media Features are governed by
the privacy policy of their respective providers.
EMAIL
MARKETING
We offer electronic newsletters to which you may voluntarily subscribe
at any time. We are committed to keeping your e-mail address confidential and
will not disclose your email address to any third parties except as allowed in
the information use and processing section or for the purposes of utilizing a
third-party provider to send such emails. We will maintain the information sent
via e-mail in accordance with applicable laws and regulations.
In compliance with the CAN-SPAM Act, all e-mails sent from us will
clearly state who the e-mail is from and provide clear information on how to
contact the sender. You may choose to stop receiving our newsletter or
marketing emails by following the unsubscribe instructions included in these
emails or by contacting us. However, you will continue to receive essential
transactional emails.
PUSH
NOTIFICATIONS
We offer push notifications to which you may also voluntarily subscribe
at any time. To make sure push notifications reach the correct devices, we use
a third-party push notifications provider who relies on a device token unique
to your device which is issued by the operating system of your device. While it
is possible to access a list of device tokens, they will not reveal your
identity, your unique device ID, or your contact information to us or our
third-party push notifications provider. We will maintain the information sent
via e-mail in accordance with applicable laws and regulations. If, at any time,
you wish to stop receiving push notifications, simply adjust your device
settings accordingly.
AFFILIATE
LINKS
We may engage in affiliate marketing and have affiliate links present on
the Website and Services for the purpose of being able to offer you related or
additional products and services. If you click on an affiliate link, a cookie
will be placed on your browser to track any sales for purposes of commissions.
LINKS TO
OTHER RESOURCES
The Website and Services contain links to other resources that are not
owned or controlled by us. Please be aware that we are not responsible for the
privacy practices of such other resources or third parties. We encourage you to
be aware when you leave the Website and Services and to read the privacy
statements of each and every resource that may collect Personal Information.
INFORMATION
SECURITY
We secure information you provide on computer servers in a controlled,
secure environment, protected from unauthorized access, use, or disclosure. We
maintain reasonable administrative, technical, and physical safeguards in an
effort to protect against unauthorized access, use, modification, and
disclosure of Personal Information in our control and custody. However, no data
transmission over the Internet or wireless network can be guaranteed.
Therefore, while we strive to protect your Personal Information, you
acknowledge that (i) there are security and privacy limitations of the Internet
which are beyond our control; (ii) the security, integrity, and privacy of any
and all information and data exchanged between you and the Website and Services
cannot be guaranteed; and (iii) any such information and data may be viewed or
tampered with in transit by a third party, despite best efforts.
As the security of Personal Information depends in part on the security
of the device you use to communicate with us and the security you use to
protect your credentials, please take appropriate measures to protect this
information.
DATA BREACH
In the event we become aware that the security of the Website and
Services has been compromised or Users’ Personal Information has been disclosed
to unrelated third parties as a result of external activity, including, but not
limited to, security attacks or fraud, we reserve the right to take reasonably
appropriate measures, including, but not limited to, investigation and
reporting, as well as notification to and cooperation with law enforcement
authorities. In the event of a data breach, we will make reasonable efforts to
notify affected individuals if we believe that there is a reasonable risk of
harm to the User as a result of the breach or if notice is otherwise required
by law. When we do, we will send you an email.
CHANGES AND
AMENDMENTS
We reserve the right to modify this Policy or its terms related to the
Website and Services at any time at our discretion. When we do, we will revise
the updated date at the bottom of this page. We may also provide notice to you
in other ways at our discretion, such as through the contact information you have
provided.
An updated version of this Policy will be effective immediately upon the
posting of the revised Policy unless otherwise specified. Your continued use of
the Website and Services after the effective date of the revised Policy (or
such other act specified at that time) will constitute your consent to those
changes. However, we will not, without your consent, use your Personal
Information in a manner materially different than what was stated at the time
your Personal Information was collected.
ACCEPTANCE
OF THIS POLICY
You acknowledge that you have read this Policy and agree to all its
terms and conditions. By accessing and using the Website and Services and
submitting your information you agree to be bound by this Policy. If you do not
agree to abide by the terms of this Policy, you are not authorized to access or
use the Website and Services.
CONTACTING
US
If you have any questions regarding the information, we may hold about
you or if you wish to exercise your rights, you may use the following data
subject request form to submit your request:
If you have any other questions, concerns, or complaints regarding this
Policy, we encourage you to contact us using the details below:
We will attempt to resolve complaints and disputes and make every
reasonable effort to honour your wish to exercise your rights as quickly as
possible and in any event, within the timescales provided by applicable data
protection laws.
This document was last updated on June 23, 2022