Your privacy is important to The Hacienda at Warm Sands. (“The Hacienda” or “we”). We developed this Privacy Statement to provide you with information on when and how we collect and process personal data when you use our website and/or stay as a guest at our hotel.
“Personal data” is information relating to an identified or identifiable natural person.
Categories of Personal Data Processed by The Hacienda
Personal Data that is Processed when you Communicate with The Hacienda
When you interact with us via email, telephone or online (e.g., when you send us an email inquiry, provide us with feedback on your stay and our services, and comment on our social media blog posts), we collect personal data. This data includes your name, the name of others who will be staying with you at The Hacienda, phone number, email address and your home address; and information specific to your reservations for a stay at The Hacienda. Additionally, when you make a reservation and pay with a credit card, we collect, but do not store your credit card data. We transfer your credit card data to a third-party electronic payment vendor that processes electronic commercial payments, as described more fully in the Third-Party Recipients of Personal Data section of this Privacy Statement.
We also may create event logs that are useful in diagnosing visit or service-related issues, and capture information relating to guest service issues. To improve our guest services, subject to applicable laws, we analyze any feedback provided to us through voluntary surveys concerning your stay and our guest services.
Purposes and Legal Grounds
We use the personal data we process to provide you with guest support services, to respond to your inquiries, and to monitor and improve the quality and types of guest services that we provide. The legal ground for processing this information for these purposes is The Hacienda’s legitimate interest in providing quality lodging experiences, outstanding guest service support, and ensuring guest satisfaction.
The Hacienda processes your email address and uses this information to correspond with you concerning your reservations and special requests for your stay. The legal ground for processing your email address for this purpose is The Hacienda’s legitimate interest in contacting you regarding your upcoming stays at The Hacienda.
With your approval, The Hacienda also processes your contact information for sending you information about The Hacienda. The name you provide is associated with your account profile. The legal ground for processing your contact information for these purposes is The Hacienda’s legitimate interest in providing you information about The Hacienda’s services or special offers.
If you are a guest of The Hacienda who pays for your stays via a credit card, The Hacienda will collect and transfer your credit card data to a third-party electronic payment vendor that processes your credit card information for payment of your guest charges during your stays. The Hacienda itself does not store any credit card data. The legal ground for processing your credit card information is that such processing is necessary for payment of your guest charges.
If you choose to sign up for our newsletter or any other communication from us, we will use your contact information for purposes of sending you the information you have requested. The Hacienda may also use your email address and other contact information for sending you occasional electronic marketing communications. You will have the opportunity to opt out of receiving any such communications at the time we collect your contact information and within every such email you receive from The Hacienda. The legal ground for processing your email address and other contact information for this purpose is our legitimate interest in sending electronic marketing communications to customers concerning The Hacienda. If you do not initially opt out of receiving electronic marketing communications, but subsequently decide that you no longer wish to receive electronic marketing communications, you will have the opportunity to opt out from receiving electronic marketing communications from The Hacienda at any time by clicking on the Unsubscribe link at the bottom of each email.
The electronic marketing communications you receive from The Hacienda may be based on information that you provide to us when you sign up for a stay at The Hacienda (e.g., the city/state/country where you live. The legal ground for processing your personal data for this purpose is The Hacienda’s legitimate interest in providing its guests with information they have requested and with electronic marketing communications that are likely to be of interest to them.
Third-Party Recipients of Personal Data
Third-party Electronic Payment Vendor
We use a third-party electronic payment vendor to process credit card data when our guests make a reservation and/or stay at The Hacienda and make payment for their guest charges using credit cards.
Third-party Service Providers
We share your personal data with Rezovation, a reservation service, in order to process your reservations.
Third Parties in Connection with a Business Reorganization
We also may transfer or provide access to your personal data to a third party in connection with an actual or impending reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of The Hacienda’s business or assets, including, without limitation, in connection with any bankruptcy or similar proceeding. Any entity to which we transfer personal data will not be permitted to process your personal data other than as described in this Privacy Statement without providing you notice and, if required by applicable laws, obtaining your consent.
Governmental Entities and Third Parties
We may disclose personal data about you to governmental entities, such as regulatory agencies, law enforcement and judicial authorities, including to meet national security or law enforcement requirements, as well as other third parties under any of the following conditions: (a) if we have your valid consent to do so; (b) to comply with a valid subpoena, legal order, court order, search warrant, legal process or other legal obligation; (c) to enforce any of our terms and conditions or policies; (d) as necessary in the case of emergencies or internal security matters; or (e) as necessary to pursue available legal remedies or defend legal claims.
We automatically collect usage data (e.g., IP address, browser details) when you interact online with our site using cookies. Cookies are small computer files sent or accessed from your web browser on your computer’s, mobile device’s, or tablet’s hard drive that contain information about your computer, such as user ID, user settings, browsing history and activities conducted while using our website. A Cookie typically contains the domain name (internet location) from which the Cookie originated, the “lifetime” of the Cookie (e.g., when it expires) and a randomly generated unique number or identifier.
Purposes and Legal Grounds
We use this usage data to facilitate communication between your device and our website, store your preferences, authenticate users, combat spam, detect and prevent fraud (e.g., fraudulent credit card use), and analyze overall usage of and improve and enhance our website.
If you are in the EU or another country that requires obtaining your consent before processing your usage data, we process your usage data based on your consent. You may withdraw your consent at any time by contacting The Hacienda via email (firstname.lastname@example.org) or writing to The Hacienda (Attn: Privacy Support), PO Box 1645, Palm Springs, CA 92263.
Your Control of Cookies
To access The Hacienda site to make a reservation, you need to enable cookies (which most web browsers do by default). Web browsers allow some control of most cookies through browser settings. Some web browsers (including mobile web browsers) provide settings that allow you to reject cookies or that alert you when a cookie is placed on your computer, tablet, or mobile device. You may be able to reject mobile device identifiers by activating the appropriate setting on your mobile device.
When you visit our website, cookies may also be placed on your computer by third-party services that are integrated into the site you are visiting. For example, third-party cookies are used by Google Analytics for tracking website traffic. We use information collected from such third-party services to help us better understand how users find and use our website, enhance our website and guest services and better understand and improve our users’ web experience.
Cross-Border Transfers of Personal Data
Your personal data may be transferred to and stored on servers at The Hacienda in the United States. The data protection and privacy laws of the United States may not be as comprehensive as the laws in other countries including the country where you live. For example, personal data transferred to the United States may be subject to lawful access requests by federal and state authorities in the United States.
Our website is not directed to individuals under the age of 18, and we request that individuals under 18 not provide personal data to The Hacienda. If we learn that we have collected personal data from a child under 18, we will take steps to delete the information as soon as possible.
Retention of Personal Data
The Hacienda will retain your personal data for only as long as needed for the purposes for which the personal data is processed and to meet The Hacienda’s legal obligations. See section below under “Your Rights” for additional information pertaining to the right of erasure, as well as other data subject rights.
We implement appropriate technical and organizational measures designed to assist in maintaining the security and confidentiality of personal data; safeguarding against anticipated threats to the confidentiality, integrity and availability of personal data; and protecting your personal data against accidental or unlawful destruction, loss, alteration, and unauthorized disclosure or access. Such technical and organizational measures include all applicable security requirements in accordance with the Payment Card Industry Data Security Standard.
However, whenever personal data is processed, there is a risk that such data could be lost, misused, modified, hacked, breached, and/or otherwise accessed by an unauthorized third party. No system or online transmission of data is completely secure. In addition to the technical and organizational measures that The Hacienda has in place to protect your personal data, you should use appropriate security measures to protect your personal data. If you believe that your The Hacienda account, or any information you provided to us, is no longer secure, please notify us immediately by emailing The Hacienda at: email@example.com or writing to The Hacienda (Attn: Privacy Support), PO Box 1645, Palm Springs, CA 92263.
Right to Object
If you reside in the European Union, you have a right to object to the processing of your personal data for direct marketing purposes, including profiling related to direct marketing, “Profiling” means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a data subject, such as when we provide you with a specific type of direct marketing information based on information you provided us when you signed up for a stay at The Hacienda (e.g, your home address location). If you exercise your right to object to processing for direct marketing purposes, including profiling related to direct marketing, The Hacienda will no longer process your personal data for such purposes.
Additionally, if you reside in the European Union, you have a right to object when we process your personal data based on the legitimate interests of The Hacienda or a third party. If you exercise your right to object where our processing or sharing of your personal data is based on legitimate interests, that will result in the elimination of The Hacienda’s records of your preferences. The Hacienda will no longer process or share the personal data covered by your objection unless The Hacienda has compelling legitimate grounds for the processing or sharing that override your objection or that relate to the establishment, exercise or defense of legal claims.
If you live in the European Union and wish to exercise your right to object, please contact The Hacienda by emailing firstname.lastname@example.org or writing to The Hacienda (Attn: Privacy Support), PO Box 1645, Palm Springs, CA 92263.
If you reside outside of the European Union, you may have a similar right to object under your local laws. If you do not live in the European Union, but you think you have a right to object under your local laws, please contact The Hacienda by emailing email@example.com or writing to The Hacienda (Attn: Privacy Support), PO Box 1645, Palm Springs, CA 92263.
Other Data Subject Rights
If you reside in the European Union, you may also, under certain circumstances specified within the General Data Protection Regulation, have the right to request access to and rectification or erasure of your personal data, data portability, restriction of processing of your personal data, and the right to lodge a complaint with a supervisory authority. If you live in the European Union, and if you wish to exercise any of these rights, please contact The Hacienda by emailing firstname.lastname@example.org or writing to The Hacienda (Attn: Privacy Support), PO Box 1645, Palm Springs, CA 92263.
If you reside outside of the European Union, you may have similar rights under your local laws. For example, if you reside in Australia, Canada or New Zealand, you have a right to access and to seek correction of your personal data. If you wish to exercise those rights in those countries
or if you live outside the European Union and think you have any data subject rights under your local laws, please contact The Hacienda by emailing email@example.com or writing to The Hacienda (Attn: Privacy Support), PO Box 1645, Palm Springs, CA 92263.
California Privacy Rights
Do Not Track
The Hacienda does not track its customers over time or across third-party websites and online services (e.g., mobile apps), and therefore does not respond to Do Not Track (DNT) signals. However, some third-party sites and apps may track your browsing activities when they provide you content, which enables them to tailor what they present to you. Third parties may collect personal data relating to your online activities over time and across different websites and apps when you use our site.
If your personal data was collected by and on behalf of The Hacienda (e.g., personal data of a guest collected through our website), then such personal data is controlled by The Hacienda, which is located at 586 Warm Sands Drive, Palm Springs, CA 92264 and which you can contact by email at firstname.lastname@example.org or writing to The Hacienda (Attn: Privacy Support), PO Box 1645, Palm Springs, CA 92263.
Privacy Statement Updates
We may update this Privacy Statement from time to time as we add new services, as we improve our current services and as technologies and laws change. You can determine the effective date of this Privacy Statement by referring to the “Effective Date” legend at the top of this Privacy Statement.
We will provide notice to you if these changes are material and, where required by applicable law, we will obtain your consent. Such notice will be provided on the The Hacienda’s website.
You can contact us with any questions or requests relating to this Privacy Statement by email at email@example.com or writing to The Hacienda (Attn: Privacy Support), PO Box 1645, Palm Springs, CA 92263.
~ June 13, 2018