Last Modified: 22/08/2023
SCOPE OF THIS POLICY
This privacy policy describes the processing of information provided or collected on the sites and applications where this privacy policy is posted, whether on our digital properties or on applications we make available on third-party sites or platforms. It also describes the processing of guest information provided to us or collected by us offline in our physical properties, such as in our stores, theme parks, resorts, and cruise ships, or through our guest call centres. We follow this privacy policy in accordance with applicable law in the places where we operate. In some cases, we may provide additional data privacy notices specific to certain products, practices, or regions. Those terms are to be read in conjunction with this policy.
Please keep in mind that when you provide information to us on a third-party site or platform, the information you provide may be separately collected by the third-party site or platform. The information we collect is covered by this privacy policy, and the information the third-party site or platform collects is subject to the third-party site or platform’s privacy practices. Privacy choices you have made on the third-party site or platform will not apply to our use of the information we have collected directly through our applications. Please also keep in mind that our sites and applications may contain links to other sites not owned or controlled by us and we are not responsible for the privacy practices of those sites. We encourage you to be aware when you leave our sites or applications and to read the privacy policies of other sites that may collect your personal information.
We collect two basic types of information– personal information (as defined in this policy) and anonymous information (as defined in this policy) – and we may use personal and anonymous information to create a third type of information, aggregate information (also defined in this policy). In particular, we collect:
· Registration information you provide when you create an account, enter a promotion with your registration account, such as your first name and surname, country of residence, gender, date of birth, email address, username, and password;
· Transaction information you provide when you request information, contact Guest Services, or purchase, return, request, or exchange a product or service from us, such as your postal address, telephone number, and payment information;
· Information you provide in public forums on our sites and applications, such as your public posts;
· Information sent either one-to-one or within a limited group using our message, chat, post, or similar functionality, where we are permitted by applicable law to collect this information;
· Information we obtain from a third party, such as a site or platform provider, about use of our applications on third-party platforms or devices;
· Location information, including precise or approximate location information provided by a mobile or other device interacting with one of our sites, applications, or physical properties (including through beacon technologies), or associated with your IP address or other online or device identifier, where we are permitted by law to process this information;
· Activity information about your use, and the use by any person(s) you authorise through your account of our sites and applications, such as the content you view or post, how often you use our services, and your preferences;
· Usage, viewing, technical, and device data when you visit our sites, use our applications on third-party sites or platforms, or open emails we send, or connect with our wireless Internet access services and other similar technologies, including your browser or device type, unique device identifier, and IP address;
· Still or video images captured by cameras or readers on or around our physical properties; and
· Call recordings when you call our reservation centres or other guest services phone numbers.
· We collect information you provide to us when you request or purchase products, services, or information from us, register with us (including when you link your profile on a third-party site or platform with your registration account), participate in public forums or other activities on our sites and applications, respond to guest surveys, visit our physical properties, call our reservation centres or other guest services phone numbers, or otherwise interact with us using one or more devices. You may provide information in a variety of ways, including by typing or using voice commands.
· We collect information through a variety of technologies, such as cookies, Flash cookies, pixels, tags, software development kits, application program interfaces, and Web beacons, including when you visit our sites and applications or use our applications on third-party sites or platforms using one or more devices, whether or not you are logged in or registered.
· We collect information using analytics tools, including when you visit our sites and applications or use our applications on third-party sites or platforms.
· We acquire information from other trusted sources to update or supplement the information you provided or we collected automatically, such as when we validate postal address information using third party services. Applicable law may require that you authorise the third party to share your information with us before we can acquire it.
GDS that is the data controller for your information is responsible for and may use your information for the purposes described in this policy. Other parties may access your information where they perform services on behalf of the data controllers (as data processors) and, unless prohibited under applicable law, for use on their own behalf (as data controllers) for the purposes described in this policy. Consistent with applicable law and choices and controls that may be available to you, we may use information collected from you, or from devices associated with you, to:
· Provide you with the experiences, products, and services you request, view, engage with, or purchase;
· Communicate with you about your account or transactions with us and send you information or request feedback about features on our sites and applications or changes to our policies;
· Send you offers and promotions for our products and services or third-party products and services;
· Personalise content and experiences;
· Provide you with targeted advertising based on your activity on our sites and applications and on third-party sites and applications;
· Operate, understand, optimise, develop, or improve our sites, applications, products, services and operations, including by using guest survey research and analytics tools; and
· Detect, investigate and prevent activities that may violate our policies, pose safety issues, or be fraudulent or illegal; and
· Notify you of product recalls or safety issues.
We will not share your personal information with a third party outside except in limited circumstances, including:
· When you allow us to share your personal information with another company, by electing to share your personal information with carefully selected companies so that they can send you offers and promotions about their products and services;
· When you direct us to share your personal information with another company to fulfil your request, such as:
· When you book travel packages with us that include goods or services provided by third-party partners, such as airlines, ground transportation providers, third-party hotels, and travel insurance providers; and
· When you book dining reservations through us for restaurants operated by third parties.
· When you direct us to share your personal information with third-party sites or platforms, such as social networking sites.
· Please note that once we share your personal information with another company in the above circumstances, the information received by the other company is controlled by that company and becomes subject to the other company’s privacy practices.
· When you use the NHK World Premium service, GDS may share information with its business partners that help offer the NHK World Premium service, including for example, its content programmers, distributors and device partners, and corporate owners; with your consent, GDS may also share your viewing information together with certain personal information with these and other third parties;
· When companies perform services on our behalf, like package delivery, marketing and advertising, and customer service; however, these companies are prohibited from using your personal information for purposes other than those requested by us or required by law; and
· When we share your personal information with third parties in connection with the sale of a business, to enforce our Terms of Use or rules, to ensure the safety and security of our guests and third parties, to protect our rights and property and the rights and property of our guests and third parties, to comply with legal process, or in other cases if we believe in good faith that disclosure is required by law.
We provide you the ability to exercise certain controls and choices regarding our collection, use and sharing of your information. In accordance with applicable law, your controls and choices may include:
· Correcting, updating, and deleting your registration account;
· Choosing or changing your choices for subscriptions, newsletters, and alerts;
· Choosing whether to receive from us offers and promotions for our products and services, or products and services that we think may be of interest to you;
· Choosing whether we share your personal information with other companies so they can send you offers and promotions about their products and services;
· Controlling targeted advertising from many ad networks and partners; data exchanges; and marketing analytics and digital advertising and marketing service providers
· Choosing to control targeted advertising you receive within applications by using the settings and choices made available to you through your device(s), for example, by re-setting your device’s advertising identifier and/or opting out of interest based ads;
· Managing your account preferences regarding the sharing of your viewing information together with certain personal information by logging into your account on your computer, going to your account settings, and editing your profile;
· Requesting removal of your personal information from a public forum on one of our sites or application; and
· Requesting access to the personal information we hold about you and that we amend or delete it.
You can opt out of interest based ads by visiting the or European Interactive Digital Advertising Alliance or using the opt-out mechanism in the “Interest Based Ads” link in the footer of the site you are visiting.
Please be aware that if you do not allow us to collect personal information from you, we may not be able to deliver certain experiences, products, and services to you, and some of our services may not be able to take account of your interests and preferences. If collection of personal information is mandatory, we will make that clear at the point of collection so that you can make an informed decision whether to participate. If you have questions about the specific personal information about you that we process or retain, and your rights regarding that personal information
We recognise the need to provide further privacy protections with respect to personal information we may collect from children on our sites and applications. Some of the features on our sites and applications are age-gated so that they are not available for use by children, and we do not knowingly collect personal information from children in connection with those features. When we intend to collect personal information from children, we take additional steps to protect children’s privacy, including:
· Notifying parents about our information practices with regard to children, including the types of personal information we may collect from children, the uses to which we may put that information, and whether and with whom we may share that information;
· In accordance with applicable law, and our practices, obtaining consent from parents for the collection of personal information from their children, or for sending information about our products and services directly to their children;
· Limiting our collection of personal information from children to no more than is reasonably necessary to participate in an online activity; and
· Giving parents access or the ability to request access to personal information we have collected from their children and the ability to request that the personal information be changed or deleted.
The security, integrity, and confidentiality of your information are extremely important to us. We have implemented technical, administrative, and physical security measures that are designed to protect guest information from unauthorised access, disclosure, use, and modification.We regularly review our security procedures to consider appropriate new technology and methods. Please be aware that, despite our best efforts, no security measures are perfect or impenetrable. We will retain your personal information for the length of time needed to fulfil the purposes outlined in this privacy policy unless a longer retention period is required or permitted by law.
Wherever your personal information is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of your personal information. These steps may include implementing standard contractual clauses where recognised by law, obtaining your consent, or other lawful means of transferring personal information.
From time to time, we may change this privacy policy to accommodate new technologies, industry practices, regulatory requirements or for other purposes. We will provide notice to you if these changes are material and, where required by applicable law, we will obtain your consent. Notice may be by email to you at the last email address you provided us, by posting notice of such changes on our sites and applications, or by other means, consistent