Effective Date: February 1, 2022
- when you visit or stay as a guest at one of our properties, or through other offline interactions with us related to our hospitality services (collectively, “Hospitality Services”);
- through our social media pages that we control from which you are accessing this Privacy Statement (collectively, our “Social Media Pages”);
- from third parties such as Hotel Operations Partners, Property Owners, Affiliates, and Business Services Providers.
Collectively, we refer to the Websites. our Social Media Pages, and electronic communications as the “Online Services.”
- Third-Party Sites. Websites, apps, videos (embedded or direct links), or other content (each a “Linked Site”) to which we link that are not operated by us. Linked Sites have their own personal information collection and use practices, and we are not responsible those practices. We encourage you to read each Linked Site’s privacy disclosures to understand how your personal information is processed.
- Non-Personal Information. Our processing of information that cannot be linked to an identifiable or identified individual. We may process this data for any legitimate business purpose.
Collection of Your Personal Information
We permit third parties to use tracking technologies on our websites for analytics and advertising, including to help manage and display advertisements, to tailor advertisements to your interests, and provide metrics on advertising effectiveness. The third parties use their technology to provide advertising about products and services tailored to your interests which may appear either on our websites or on other websites.
The information we collect using these technologies includes:
- Device and Browser Identifiers. For example, an assigned user ID, IP address, or similar identifier that can be used to identify your device. This includes when you connect a device to WiFi or other Internet-enabled services at our Properties.
- Coarse and Precise Location Information. We may gain a general approximation of your location that is not based on global position system (GPS) information. We may collect your precise location when you enable us to collect it via your device. You can use your device’s settings to restrict access to precise location.
- Browsing and Search History. Information about the content you view and searches you make on our Site(s).
- Website Log and Usage Data. Information related to our pages you viewed, the services and features you used or interacted with, your browser type and details about any links or communications with which you interacted.
- Advertising Metrics. Information about the advertisements you have viewed on our Website.
- Chat Modules. We may collect certain categories of personal information from you when you use our interactive chat module. By interacting with the chat box, you consent to our collection practices and understand and acknowledge that we may use this data to provide our chat functionality.
Because the “Do Not Track” browser-based standard signal has yet to gain widespread acceptance, our Website(s) currently does not respond to those signals. To learn more about your options with respect to tracking technologies, please see the Your Privacy Preferences section, below.
When you interact with us in connection with our Hospitality Services we may collect and process certain information about you. This information includes:
- Your Personal Details. These include your first and last name, email address, phone number, mailing and billing address, employer or group information (if your reservation is part of a company or group booking), and other contact information you provide.
- Government Identifiers. These include your driver’s license, passport, or other government ID information as well as your country of citizenship.
- Personal Characteristics. These include your gender, marital status, information about family members and travel companions (including children), language preferences, amenity requests, dietary restrictions, relevant dates (birthdate, anniversary, special occasions), and hospitality preferences.
- Travel Details. These include your travel itinerary, dates of travel/stay, activities and amenities booked and purchased.
- Guest History. This includes your past stays or interaction with the Property or KSL Resorts, goods or services purchased, services and requests, feedback or communications from prior stays.
- Financial Information. This includes credit and debit card number or other payment data.
- Survey data. We may contact some individuals to request participation in a survey or other general research. If you choose to take part in these, you may provide personal information, in or along with your survey responses, or in any other feedback or comments you give us.
- Contests, sweepstakes, and prize drawings data. If you take part in a contest, sweepstakes, or prize drawing, then you may provide personal information, feedback, or comments to enter, or as part of the contest, sweepstakes, or prize drawing.
- Messages and email data. We collect information about you when you send, receive, open, read or otherwise engage with messages, email, or other communications in connection with our Services, including whether you have opened or acted on those communications.
- Social Media Content. For example, interactions with our Social Media Pages and content you post on them. This information may include your social media handle, account ID, publicly available photos and other data made public by you on your social media.
- Other Personal Information You Provide. If you provide us personal information other than that described above, we will collect it and use it for the purposes for which you provide it or other consistent purposes.
- Inferences. In certain instances, we may infer personal information about you based on the information you have provided to us or that we have collected about you.
- Security Surveillance Information. Our properties may capture audio-visual information and images of you when you visit our Properties.
We collect this information when you sign up or otherwise agree to receive marketing communications from a Property or KSL Resorts; make a reservation to stay at one of our Properties or use our Hospitality Services; interact with KSL Resorts’ or a Property’s workforce members; visit our Properties,; engage with use on social media,; participate in a promotion, contest, or sweepstakes we offer; contact our customer services teams; or submit it to us online or in-person.
We obtain the personal information described above from third parties including:
- Hotel Operations Partners. When you book through a third-party company providing hospitality services, they may share your personal information with us to facilitate your hospitality requests. These include franchisors of branded hotels.
- Property Owners. When KSL Resorts acts as the property manager or operator for a specific Property, we may receive personal information about you from the Property Owners.
- Travel Providers. These include booking and reservations services, airlines, travel agencies.
- Hospitality Service Providers. These include providers of hospitality and other services, including restaurants, spas, shops, golf courses, and similar activities providers by or through our Properties or associated with our Properties.
- Affiliates. We share personal information with other entities within the KSL Resorts portfolio.
- Business Services Providers. These are those persons or entities with whom we have a relationship to provide business operations services and support to Company. These providers may include the following:
- IT Operations Providers. These include cloud computing service providers, internet service providers, data backup and security providers, functionality and infrastructure providers, and similar service providers.
- Operations Providers. These include service provider with whom we partner to provide day-to-day business operations, including payment processors, security vendors, business software service providers, hospitality service providers, banks, facilities management providers.
- Marketing and Advertising Providers. These include advertising, direct marketing, and lead generation providers, affiliate marketing program providers, retargeting platforms, data brokers, ad networks, marketing consultants, and similar services providers.
- Publicly Available Sources. These include public databases, marketing partners, and event sponsors.
Use of Your Personal Information
We may use your personal information for a variety of reasons. Depending on how you interact with our Services, these include using personal information:
- Delivering Our Hospitality Services to you and to provide the related customer support, communication, and security. We provide all of the services common with the hotel and hospitality industry and our use of your personal information is consistent with providing our hospitality services.
- Customer Service to provide customer service, maintain and service products and accounts, provide training for quality assurance purposes, and perform similar activities.
- Processing Transactions to process or fulfill orders and transactions, verify customer information, process payments, confirm eligibility promotional benefits, and perform similar activities.
- Policy Enforcement including enforcing our terms of stay and service, acceptable use policies, anti-spam policies, and similar policies.
- Advertising & Marketing to send advertisements and marketing material via physical and electronic mail relating to product specials and other promotional events or offers, perform marketing research and data analytics, and perform similar activities.
- Contextual and Behavioral Targeting to provide contextual customization of ads shown as part of an interaction with our website or application, using tracking technologies like cookies and pixels.
- Counting Ad Impressions & Website Interactions to audit interactions with our websites, applications, or advertisements, count ad impressions to unique visitors, verify position and quality of ad impressions, and perform similar activities.
- >strong>Fraud Prevention to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and to prosecute those responsible for that activity.
- Public Health and Safety to ensure the health and safety of our guests, our workforce members, and the general public.
- Defending Against Claims & Litigation to defend against or respond to potential or actual claims and litigation.
Our Legal Grounds for Processing Your Personal Information
When we process personal information about you to comply with legal requirements or to perform our obligations under a contract with you or with our customer through whom you use our offerings, failure to provide such information may prevent or delay our fulfillment of these obligations. To the extent required by applicable law, we will collect your personal data with your consent, where required, and in accordance with our legitimate need to provide our Services.
Under European data protection laws, KSL Resorts is required to rely on one or more legal bases to collect, use, share, and otherwise process the information we have about you. We describe these legal bases and some accompanying examples in more detail below.
Performance of Contract. KSL Resorts processes your information as is necessary to perform our contract with you, including:
- Facilitating reservations and bookings of accommodations and related services.
- Processing payments and security deposits.
Your Consent. KSL Resorts processes certain information based on your consent, which you may revoke at any time. For example:
- Where you choose a method of verification to confirm your address, we do so in accordance with your consent.
- If you decide to use location services in the context of KSL Resorts, we collect and process such location information based on your consent.
- We rely on your consent to tailor ads based on your activity and information on other websites and partner data, such as inferred interests.
- We will send you marketing communications where you have consented to receiving such communications in accordance with applicable law.
Legal Obligation. KSL Resorts may process your information to comply with a legal obligation, a court order, or to exercise and defend legal claims. For example:
- We may preserve and disclose your information if it is necessary to respond, based on applicable law, to a valid legal request (e.g., a subpoena, search warrant, court order, or other binding request from government or law enforcement).
- We may retain and process your information where it is necessary for compliance with applicable tax or records retention laws.
Vital Interests. KSL Resorts may process your information in certain circumstances when it is necessary to protect your vital interests, or those of others. For example:
- We may need to process your information in order to protect your life or safety or the lives or safety of others, or otherwise prevent physical injury or other harm to any person or the general public.
- We may preserve or share your information with law enforcement and related authorities where we have a good faith belief that it is required in the context of an imminent threat.
- We may share your personal data with disaster relief agencies, first responders and other individuals to facilitate disaster or emergency response efforts.
Legitimate Interests. We may process your information where it is necessary for the purposes of KSL Resorts. We process your information in furtherance of the following legitimate interests:
- Providing, improving, and developing our Online Services.
- Providing, improving, and developing our Hospitality Services.
- General Business Operations.
- Sending marketing communications. This includes marketing and promoting our brands, Properties, and Hospitality Services. We use your contact information and send you marketing communications in accordance with applicable law, except where applicable law requires that we rely on your consent to send such communications.
- Customer Service. This includes responding to customer complaints or concerns, fulfilling guests’ preferences, monitoring Properties for safety and security purposes, and enforcing policies and procedures for the benefit of our workforce members, other guests, and protection of property.
- Providing promotions, contests, and sweepstakes. We may also rely on consent, when required by law, when processing personal information for these purposes.
KSL Resorts does not have an establishment in the European Economic Area, the United Kingdom, or Switzerland, nor do we target our activities to those jurisdictions. Nevertheless, you may submit requests related to rights provided under the General Data Protection Regulation (GDPR) (as implemented in the country or region applicable to you) consistent with this policy. If you would like to lodge a complaint with the appropriate data protection authority for your country or region or where an alleged infringement of applicable data protection laws occurs, please contact your local data protection authority.
For the EEA, a list of the national data protection authorities can be found at: https://ec.europa.eu/newsroom/article29/items/612080.
For the UK, the responsible data protection authority is the Information Commissioner’s Office (ICO), more details about which can be found on the ICO website. Our notice to you consistent with the obligations of data controllers under the GDPR or other laws applicable to data subjects located in the EEA, UK, or Switzerland is not an admission as to the application of foreign data protection laws on KSL Resorts.
Disclosure of Personal Information
We may share your personal information with the following:
- Hotel Operations Partners.
- Property Owners.
- Travel Providers.
- Hospitality Service Providers.
- Business Services Providers.
- Marketing and Advertising Providers.
- Professional Advisors. These include lawyers, accountants, consultants, security professionals, and other similar parties when disclosure is reasonably necessary to comply with our legal and contractual obligations, prevent or respond to fraud or abuse, defend ourselves against attacks, or protect the rights, property, and safety of us, our customers, and the public.
- Legally Required Parties/Governmental Entities. Persons to whom we are required by law to provide information, such as pursuant to a subpoena or a court order.
- Reorganization. Persons involved in the consideration, negotiation, completion of a business transaction, including the sale, merger, consolidation, acquisition, change in control, transfer of substantial assets, bankruptcy, or reorganization, and any subsequent integration.
- Authorized Disclosures. To any party when authorized by the individual to whom it pertains to share it.
We will retain your personal information only for so long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information; the potential risk of harm from unauthorized use or disclosure of your personal information; the purposes for which we process your personal information and whether we can achieve those purposes through other means; and the applicable legal requirements. In some circumstances, you may ask us to delete your information. Additionally, we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
We have implemented and maintain reasonable security procedures and practices, appropriate to the nature of the information, to protect your personal information from unauthorized access, destruction, use, modification, or disclosure. However, no security measure is perfect, so we cannot guarantee the security of your personal information. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the “Contact Us” section, below.
International Data Transfers
We are located and operate in the United States. By submitting personal information to us, you understand that we may transfer your personal information to country foreign to you, including the United States, for processing. The laws that apply to the use and protection of personal information in the United States, or other countries or jurisdictions in which we transfer or process personal information, may be different from the laws and protections in your country. These transfers may include transfers to our service providers located in foreign jurisdictions. Whenever we engage a service provider, we require that its privacy and security standards adhere our requirements and applicable privacy laws.
Your Privacy Preferences
You can control the collection and use of personal information for some of our processing activities. This includes:
Adjusting Communication Preferences
Emails From KSL Resorts: During the registration for KSL Resorts, you should be presented with an opt-in to receive email communications. If you wish to no longer receive email communications, you can click on the “unsubscribe” link located at the bottom of the email, email KSL Resorts at email@example.com to let us know, and we will remove you as soon as possible. Opting out of marketing or newsletter emails will not opt-you out of all emails—we may need to send you transactional or similar emails related to your KSL Resorts’ or a Property’s account, purchases, legal or contractual updates, or similar topics. You are not able to opt-out of these emails.
Text Messages: You may opt out of automated text notifications any time by replying “STOP,” or any alternative keyword we have shared with you. You may still receive communications from KSL Resorts regarding safety issues, such as messages related to your account, even if you have opted out.
Opting Out of Cookies
There are several ways to opt-out of cookies. If, however, you do not accept any cookies, you may experience some inconvenience in your use of the Online Services. For example, we will not be able to recognize your computer, and you will need to log in every time you visit. You also will not receive advertising or other offers from us that are relevant to your interests.
This Website recognizes the Global Privacy Control.
Browser settings: You can opt out of cookies on your browser. Every browser is different so please check the instructions provided by your browser.
Your Privacy Rights
Some jurisdictions provide covered individuals with specific privacy rights which can be exercised against covered entities. Depending on the jurisdiction, these rights may include the following:
- Access. The right to know (or confirm) what personal information an entity has collected about you, and to receive a copy of it.
- Deletion. The right to request that an entity delete personal information it has collected from you.
- Restriction. The right to request an entity restrict how it uses certain personal information. In California, this right is referred to as the right to limit the use of sensitive personal information.
- Correction. The right to request correction of inaccurate personal information maintained by an entity.
- Opt-Out of the Sale/Sharing of Your Personal Information. The right to opt-out of the sale of your personal information to third parties. The term “sale” varies by jurisdiction, but sometimes includes the right to opt-out of the use of personal information for targeted advertising purposes (“sharing”).
- Revoke Consent. Where consent is required for processing under applicable law, the right to withdraw your consent.
- Object to Processing. The right to object to the processing of personal information by an entity under applicable law.
- Opt-out of Profiling/Automated Decision-Making: The right to opt- out of profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
- Non-Discrimination. The right not to be discriminated against for exercising any of the rights conferred at law.
- Complaints. The right to lodge a complaint with the appropriate governmental authority.
KSL Resorts will honor the privacy rights afforded to individuals in accordance with applicable law and will not discriminate against individuals for exercising their privacy choices under the law.
Exercising Your Privacy Rights
Access, Deletion, Restriction, Correction, and Objection Requests
You or an authorized agent may make a request at any time to exercise the rights listed above by emailing us at Info@kslresorts.com or by submitting a request through [our privacy portal]. We will respond to your request within a reasonable period (if properly submitted) and in accordance with applicable law. If we need more time to process and respond to your request, we will notify you of that fact along with the reason for the delay. If we decline to act regarding your request, we will inform you of our decision and the reason for it, and, if applicable, with instructions on how you may appeal our decision.
Opting Out of Sale, Sharing, and Targeted Advertising
To make a request to opt-out of sale and/or sharing of personal information email us at Info@kslresorts.com
Our Services are not intended for persons under 16 years of age. We do not knowingly collect or process the personal information of individuals under the age of 16. If we learn that we have collected personal information from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us their Personal Information, please contact us at firstname.lastname@example.org.
Changes to this Notice
KSL Resorts, Inc.
Mail: KSL Resorts, Inc. 18565 Jamboree Road, Suite 500, Irvine, CA 92612
Telephone: (949) 617- 5100