We may share information with our affiliated companies and others for their direct marketing use unless you tell us not to. California residents who have an existing business relationship with us may opt out of such sharing by emailing us at ca-datarequest@langhamhotels.com. We will process your request promptly.
As of January 1, 2020 verified California residents have the right to:
For purposes of the CCPA personal information means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.
In order to make a request for disclosure California residents may contact us by calling us toll-free at (+1) 833-906-2154 or by visiting our CCPA request page here. We will ask you for information that allows us to reasonably verify your identity (that you are the person about whom we collected personal information) and will use that information only for that purpose. We may request that you submit a signed statement under penalty of perjury that you are the individual you claim to be. We will acknowledge receipt of your request within 10 days and will endeavor to respond within 45 days of receipt of your request, but if we require more time (up to an additional 45 days) we will notify you of our need for additional time. For requests that we not sell your information we will comply with your request within 15 days. We cannot respond to your request or provide you with personal information if we cannot verify your identity and confirm that the personal information relates to you.
You may make a request for disclosure of the information we collected about you, or our sharing practices in respect of that data up to twice within a 12-month period. You may make a request that we not sell information or for deletion of your information at any time.
For requests for a copy of the personal information we have collected during the 12 months prior to your request we will endeavor to provide the information in a format that is readily useable, including by mailing you a paper copy or providing an electronic copy to your registered account, if you have registered an account with us.
For requests for deletion of your information please understand that California law permits us to retain certain information and not to delete it under certain circumstances. By way of example, we are not required to comply with a request to delete information if the information is necessary for us to complete a transaction for you or otherwise perform a contract; to detect, protect against, or prosecute security incidents, fraud or illegal activity; to use the information only internally in ways reasonably aligned with your expectations as our customer (such as maintaining sales records), and to comply with legal obligations. If we receive such a request from you we will notify any service providers we have engaged to delete your information as well.
We will not discriminate against you as a result of your exercise of any of these rights.
OR call our toll-free number at (+1) 833-906-2154
We do not sell you information for monetary consideration but we may transfer your information to a third party that provides us with services such as helping us with advertising, data analysis and security, which may fall under the definition of for “other valuable consideration” which may be considered a ‘sale’ under the CCPA. During the past 12 months we disclosed Identifiers, Commercial Information, Electronic Network Activity, Geolocation with third parties for a business purpose which may fall within the definition of a ‘sale’. If you are a California resident over the age of 16 and would like to instruct us not to sell your personal information, please visit our Do-Not-Sell web page here. We do not sell personal information of individuals we actually know are less than 16 years of age. If you request that we not sell your information we will honor your request within 15 days, will notify those who received your information in the 90 days before your request to not further sell your information and will notify you when this has been completed. Once we receive your Do-Not-Sell request we will wait at least 12 months before asking you to reauthorize personal information sales.
VISIT OUR DO-NOT-SELL WEB PAGE
OR call our toll-free number at (+1) 833-906-2154
You may submit a request through someone holding a formal Power of Attorney. Otherwise, you may submit a request using an authorized agent only if (1) you provide the authorized agent with written permission to make a request and (2) you verify your own identity directly with us. We will require the agent to submit proof to us that they have been authorized to make requests on your behalf.
During the past 12 months, we have collected the following categories of information from the listed sources, used it for the listed business purposes and shared it with the listed categories of third parties. The categories of information include information we collect from our website visitors, registered users, employees, vendors, suppliers and any other person that interacts with us either online or offline. Not all information is collected about all individuals. For instance, we may collect different information from applicants for employment or from vendors or from customers.
Category of Information collected
Source
Business purposes* for use
Categories of third parties receiving information
Category of Information collected
Identifiers (name, alias, postal address, email address, phone number, fax number, account name, Social Security number, driver's license number, passport number, unique personal identifier, IP address)
Source
Individuals submitting information to us (including employment applications and employees)
information we may receive from third-party marketing and data partners (e.g., for making bookings and reservations)
Business purposes* for use
auditing relating to transactions
security detection, protection and enforcement;
ad customization
performing services for you
internal research and development
quality control
Categories of third parties receiving information
service providers (such as payment processors, mail houses, marketing partners, shipping partners, employee benefits partners)
affiliated companies
government regulators and law enforcement (when lawfully requested)
Category of Information collected
Sensitive Information (name with financial account, medical, health, and health insurance information, user name and password)
Source
individuals submitting information (including employment applications and employees)
Business purposes* for use
auditing relating to transactions
security detection, protection and enforcement
performing services for you
internal research and development
quality control
Categories of third parties receiving information
service providers (such as payment processors, employee benefits partners)
affiliated companies
government regulators and law enforcement (when lawfully requested)
Category of Information collected
Protected classification information (race, gender, ethnicity, religion)
Source
individuals submitting information (including employment applications and employees)
Business purposes* for use
auditing relating to transactions
security detection, protection and enforcement
performing services for you
quality control
Categories of third parties receiving information
service providers (such as employee benefits partners)
affiliated companies
government regulators and law enforcement (when lawfully requested)
Category of Information collected
Commercial information (transaction history, products/services purchased, obtained or considered, product preference)
Source
individuals submitting information
information we automatically collect from website visitors
information we may receive from third-party marketing or data partners
information we collect for security purposes
Business purposes* for use
auditing relating to transactions
security detection, protection and enforcement
ad customization
performing services to you
internal research and development
quality control
Categories of third parties receiving information
service providers (such as payment processors, mail houses, marketing partners, shipping partners, employee benefits partners)
affiliated companies
government regulators and law enforcement (when lawfully requested)
Category of Information collected
Electronic network activity (browsing or search history, website interactions, advertisement interactions)
Source
information automatically collected from website visitors
Business purposes* for use
functionality debugging/error repair
ad customization
internal research and development
quality control
Categories of third parties receiving information
service providers (such as marketing partners)
affiliated companies
government regulators and law enforcement (when lawfully requested)
Category of Information collected
Audio, video or similar information (customer service calls, security monitoring)
Source
individuals submitting information
information we collect for security purposes
Business purposes* for use
auditing relating to transactions
security detection, protection and enforcement
performing services for you
internal research and development
quality control
Categories of third parties receiving information
service providers (such as payment processors, employee benefits partners)
affiliated companies
government regulators and law enforcement (when lawfully requested)
Category of Information collected
Biometrics (fingerprints)
Source
information we collect from employees for administrative and/or security purposes
Business purposes* for use
security detection, protection and enforcement.
Categories of third parties receiving information
government regulators and law enforcement (when lawfully requested).
Category of Information collected
Geolocation (geo-targeting for digital and social media ads)
Source
information we automatically collect from site visitors
Business purposes* for use
ad customization
Categories of third parties receiving information
service providers (such as marketing partners)
Category of Information collected
Professional, educational or employment related information
Source
information submitted by individuals (including employment applications and employees)
information received from third party vendors (e.g., outsourced employees, recruitment agents)
information we observe in connection with vendor or employment oversight
Business purposes* for use
auditing relating to transactions
security detection, protection and enforcement
performing services for you
internal research and development
quality control
Categories of third parties receiving information
service providers (such as employee benefits partners)
affiliated companies
government regulators and law enforcement (when lawfully requested)
Category of Information collected
Inference from the above (preferences, characteristics, behavior, attitudes, abilities, etc.)
Source
Business purposes* for use
auditing relating to transactions
security detection, protection and enforcement
ad customization;
performing services for you
internal research and development
quality control
Categories of third parties receiving information
service providers (such as payment processors, mail houses, marketing partners)
affiliated companies
United States (US) federal and state privacy laws apply to the processing of information of residents of the United States. This section is meant to provide supplemental or specific information for residents of California and certain other US states. We encourage you to read the full policy for a complete picture of our privacy practices.
For purposes of the California Consumer Privacy Act (CCPA) personal information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.
During the past 12 months, we have collected the following categories of information from the listed sources, used it for the listed business purposes and shared it with the listed categories of third parties. The categories of information include information we collect from our website visitors, registered users, vendors, suppliers and any other person that interacts with us either online or offline. Not all information is collected about all individuals. For instance, we may collect different information from applicants for employment or from vendors or from customers.
If you join the loyalty programme, we may also process your personal information in accordance with section 1.5 “WHAT INFORMATION WE PROCESS, AND HOW WE PROCESS AND USE YOUR INFORMATION IF YOU ARE A LOYALTY PROGRAMME MEMBER” in the General Terms. See also section 3.2 of this Notice below for our Notice of Financial Incentive for members of our loyalty programme.
| Category of information collected | Source | Business purposes* for use | Categories of third parties receiving information |
|---|---|---|---|
Identifiers (name, alias, date of birth, postal address, email address, phone number, fax number, account name, unique personal identifier, IP address) And Information About You. Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, your name, signature, physical characteristics or description, address, telephone number, bank account number, credit card number, debit card number, or any other financial information, or medical information,. | Individuals submitting information to us Information we may receive from third-party marketing and data partners (e.g., for making bookings and reservations) | auditing relating to transactions security detection, protection and enforcement; ad customization performing services for you including operating our loyalty programme internal research and development quality control | service providers (such as payment processors, mail houses, marketing partners, shipping partners) affiliated companies government regulators and law enforcement (when lawfully requested) |
| Protected classification information (gender, ethnicity, religion, disability) | individuals submitting information | performing services for you to accommodate any special needs | service providers affiliated companies government regulators and law enforcement (when lawfully requested) |
| Commercial information (transaction history, products/services purchased, obtained or considered, product preference) | individuals submitting information information we automatically collect from website visitors information we may receive from third-party marketing or data partners information we collect for security purposes | auditing relating to transactions security detection, protection and enforcement ad customization performing services to you including operating our loyalty programme internal research and development quality control | service providers (such as payment processors, mail houses, marketing partners, shipping partners) affiliated companies government regulators and law enforcement (when lawfully requested) |
| Electronic network activity (browsing or search history, website interactions, advertisement interactions) | information automatically collected from website visitors | functionality debugging/error repair ad customization internal research and development quality control | service providers (such as marketing partners) affiliated companies government regulators and law enforcement (when lawfully requested) |
Audio, video or similar information (customer service calls, security monitoring) Geolocation (geo-targeting for digital and social media ads) | individuals submitting information information we automatically collect from website visitors information we may receive from third-party marketing or data partners information we collect for security purposes | auditing relating to transactions security detection, protection and enforcement performing services for you internal research and development quality control ad customization | service providers (such as payment processors) affiliated companies government regulators and law enforcement (when lawfully requested) service providers (such as marketing partners) |
| Inference from the above (preferences, characteristics, behaviour, attitudes, abilities, etc.) | internal analytics | auditing relating to transactions security detection, protection and enforcement ad customization; performing services for you internal research and development quality control | service providers (such as payment processors, mail houses, marketing partners) affiliated companies |
We also collect the below categories of sensitive personal information as defined under California law.
We do not use or disclose your sensitive personal information for purposes other than those necessary to provide you with benefits and services, to aid in protecting and securing your personal information and our systems, to verify or maintain the quality or safety of our services and systems, or as otherwise permitted under regulations or required by law.
| Category of sensitive information collected | Source | Business purposes* for use | Categories of third parties receiving information |
|---|---|---|---|
| Account log-in, password, or credentials allowing access to an account. | individuals submitting information (including employment applications) | auditing relating to transactions security detection, protection and enforcement performing services for you internal research and development quality control | service providers (such as payment processors, employee benefits partners) affiliated companies government regulators and law enforcement (when lawfully requested) |
| Personal information collected and analyzed concerning a consumer’s health. | individuals submitting information | performing services for you to accommodate any special needs | service providers affiliated companies government regulators and law enforcement (when lawfully requested) |
| Precise Geolocation | individuals via the mobile App | locate the hotels in proximity with guest location and sorting the offerings by these hotels. during the guest registration on the mobile App, pre-populate the location field and the country code based on the guest location | service providers |
*MORE SPECIFICALLY, THE BUSINESS PURPOSES INCLUDE:
PERFORMING SERVICES FOR YOU
ADVERTISING CUSTOMIZATION
For marketing and promotions we believe you may find of interest and to provide you, or allow selected third parties to provide you, with information about products and services that may interest you.
AUDITING RELATING TO TRANSACTIONS, INTERNAL RESEARCH AND DEVELOPMENT
SECURITY DETECTION, PROTECTION AND ENFORCEMENT; FUNCTIONALITY DEBUGGING, ERROR REPAIR
QUALITY CONTROL
We offer our customers the opportunity to participate in our loyalty programme, which provides benefits, including discounts on meals, goods or hotel services, as well as the opportunity to earn points which can be used to redeem goods or services. Those benefits are described along with other important information in the Terms and Conditions . A full list of our participating venues, along with the benefits they provide, can be found here .
In order to offer the our loyalty program to our members, we collect and process member’s personal information as described above in section 1.5 “WHAT INFORMATION WE PROCESS, AND HOW WE PROCESS AND USE YOUR INFORMATION IF YOU ARE A LOYALTY PROGRAMME MEMBER” in the General Terms.
We estimate the value of a member’s personal information to us, solely for purposes of the California Consumer Privacy Act (CCPA) and pursuant to the valuation criteria specified by the CCPA Regulations, to be on average approximately $0.39 per consumer in 2024. This estimate is not specific to any individual consumer and varies per consumer. We have based this good-faith estimate on the value that arises from our commercial relationships and the collection and retention of the personal information of consumers who have voluntarily signed up and chosen to remain in the loyalty programme. The value of programme benefits to members varies significantly as individual members take advantage of programme benefits to varying degrees.
To join our loyalty programme, you may sign up on the loyalty programme website or mobile App (including the WeChat mini program), the Guest Registration Card, our booking system, or (if you have been part of a pre-existing loyalty programme) register on our Legacy Enrolment page. Programme members can withdraw from the programme at any time via email to enquiry@brilliantbylangham.com , as well as through prescribed forms on our websites . You may also have the right to request that we delete personal information that we collect about you, as well as other rights as described in this Privacy Policy. As the personal information we collect from loyalty programme members is necessary for us to provide the programme, exercising your right to request that we delete your personal information may prohibit us from being able to continue to offer your membership in the programme.
We do “share” the below categories of personal information relating to California residents for cross-context behavioural advertising purposes. This means that we may share your personal information with our business partners in order to target advertising based on personal information obtained from your activity across businesses, distinctly‐branded websites, applications, or services, other than our websites and services with which you intentionally interact. We may also transfer your information to other third party services that provide us with data analysis and security services, which may fall under the definition of “other valuable consideration” and may be considered a “sale” under the CCPA. We do not otherwise “sell” your personal information, as defined under California law. During the past 12 months we disclosed the below categories of personal information with third parties for a business purpose which may fall within the definition of a “sale”.
You have the right to opt out of this sharing. If you are a California resident over the age of 16 and would like to instruct us not to sell your personal information, please visit our Do-Not-Sell web page here . We do not sell personal information of individuals we actually know are less than 16 years of age. If you request that we not sell your information we will honour your request within 15 days, will notify those who received your information in the 90 days before your request to not further sell your information and will notify you when this has been completed. Once we receive your Do-Not-Sell request we will wait at least 12 months before asking you to reauthorise personal information sales.
VISIT OUR DO-NOT-SELL WEB PAGE
OR call our toll-free number at (+1) 833-906-2154
| Category of information we “share” or “sell” | Third Parties With Whom We Share This Information |
|---|---|
Personal identifiers (identifiers such as a real name, alias, postal address, unique personal identifier, online identifier Internet Protocol address, email address, account name, or other similar identifiers)
| service providers (such as marketing partners) affiliated companies |
| Commercial information (transaction history, products/services purchased, obtained or considered, product preference) | service providers (such as marketing partners) affiliated companies |
| Electronic network activity (browsing or search history, website interactions, advertisement interactions) | service providers (such as marketing partners) affiliated companies |
| Geolocation (geo-targeting for digital and social media ads) | service providers (such as marketing partners) affiliated companies |
As a California resident, you may be entitled to all or some of the rights described below regarding your personal information, subject to certain conditions and limitations. Only those rights relevant to you will apply, and our inclusion of information about privacy laws does not imply that all privacy laws are applicable.
Data solely retained for data backup purposes is principally excluded from these rights until it is restored to an active system or next accessed or used for a sale, disclosure, or commercial purpose.
We will not discriminate against you as a result of your exercise of any of these rights.
HOW TO EXERCISE YOUR RIGHTS
In order to make a request for disclosure California residents may contact us by calling us toll-free at (+1) 833-906-2154 or by visiting our CCPA request page here . We will ask you for information that allows us to reasonably verify your identity (that you are the person about whom we collected personal information) and will use that information only for that purpose. We may request that you submit a signed statement under penalty of perjury that you are the individual you claim to be. We will acknowledge receipt of your request within 10 days and will endeavor to respond within 45 days of receipt of your request, but if we require more time (up to an additional 45 days) we will notify you of our need for additional time. For requests that we not sell your information we will comply with your request within 15 days.
We cannot respond to your request or provide you with personal information if we cannot verify your identity and confirm that the personal information relates to you. In order to verify your identity, you will need to submit information about yourself, including your name, contact information, and, to the extent applicable, providing your account login credentials. We will match this information against information we have previously collected about you or provided to you to verify your identity and your request. If we are unable to verify your identity as part of your request, we will not be able to satisfy your request. We are not obligated to collect additional information in order to enable you to verify your identity. For deletion requests, you will be required to submit a verifiable request for deletion and then confirm separately that you want personal information about you deleted. Information collected for purposes of verifying your request will only be used for verification.
You may make a request for disclosure of the information we collected about you, or our sharing practices in respect of that data up to twice within a 12-month period. You may make a request that we not sell information or for deletion of your information at any time.
For requests for a copy of the personal information we have collected during the 12 months prior to your request we will endeavour to provide the information in a format that is readily useable, including by mailing you a paper copy or providing an electronic copy to your registered account, if you have registered an account with us.
For requests for deletion of your information please understand that California law permits us to retain certain information and not to delete it under certain circumstances. By way of example, we are not required to comply with a request to delete information if the information is necessary for us to complete a transaction for you or otherwise perform a contract; to detect, protect against, or prosecute security incidents, fraud or illegal activity; to use the information only internally in ways reasonably aligned with your expectations as our customer (such as maintaining sales records), and to comply with legal obligations. If we receive such a request from you we will notify any service providers we have engaged to delete your information as well.
Please note that under applicable privacy law, we are only obligated to respond to personal information requests from the same consumer up to two times in a 12-month period. In addition, under applicable privacy law, and for the protection of your personal information, we may be limited in what personal information we can disclose.
California law also permits you to request in writing a list of the types of personal information that we have disclosed to a third party for their direct marketing purposes during the preceding year and to whom that information was disclosed.
VISIT OUR CCPA REQUEST PAGE OR
call our toll-free number at (+1) 833-906-2154
USING AN AUTHORIZED AGENT
You may submit a request through someone holding a formal Power of Attorney. Otherwise, you may submit a request using an authorised agent only if (1) you provide the authorized agent with written permission to make a request and (2) you verify your own identity directly with us. We will require the agent to submit proof to us that they have been authorized to make requests on your behalf.
