For California Consumers – California Consumer Privacy Statement
This California Consumer Privacy Statement supplements the Rosewood Privacy Policy and applies solely to California consumers. This California Consumer Privacy Statement does not apply to Rosewood employee.
This California Consumer Privacy Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) and its implementing regulations (collectively, the “CCPA”).
Notice of Collection and Use of Personal Information
We may collect (and may have collected during the 12-month period prior to the effective date of this California Consumer Privacy Statement) the following categories of personal information about you:
- Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers, and similar technology; guest number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, IP address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers
- Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, state identification card number, bank account number, credit card number, debit card number, other financial information, education, and medical information (for example, in connection with your special requests or accommodations)
- Protected Classifications: characteristics of protected classifications under California or federal law, such as age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, disability, citizenship status, and military and veteran status
- Commercial Information: commercial information, including guest stay information and frequent flyer details described in the Privacy Policy and other records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
- Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements, and general location information (approximately at the city level by ISO codes).
- Sensory Information: audio, electronic, visual, and similar information (such as the CCTV/surveillance and call recordings described in the Privacy Policy)
- Employment Information: professional or employment-related information such as résumé information, occupation details, education details, certifications and professional associations, historical compensation details, previous employment details, , and pre-employment screening and background check information, including criminal records information
- Education Information: in connection with job applicants, education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)
- Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
We may use (and may have used during the 12-month period prior to the effective date of this California Consumer Privacy Statement) your personal information for the purposes described in the Rosewood Privacy Policy and for the following business purposes:
- Performing services, including maintaining or servicing accounts, providing guest services, processing or fulfilling orders and transactions, verifying guest information, processing payments, providing financing, providing analytics services, providing storage, or providing similar services;
- Providing advertising and marketing services;
- Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance;
- Short-term, transient use, such as non-personalized advertising shown as part of your current interaction with us;
- Helping to ensure security and integrity;
- Undertaking activities to verify or maintain the quality or safety of our services or devices and to improve, upgrade, or enhance them;
- Debugging to identify and repair errors;
- Undertaking internal research for technological development and demonstration;
- Managing career opportunities with Rosewood; and
- Managing our relationships with current or prospective partners, corporate customers and vendors and other business partner personnel.
Retention of Personal Information
We will retain your personal information as described in the “How Long Do We Retain Your Personal Data” section of the Rosewood Privacy Policy.
Sources of Personal Information
During the 12-month period prior to the effective date of this California Consumer Privacy Statement, we may have obtained personal information about you from the following categories of sources:
- Directly from you, such as when you make a reservation or purchase, complete a form, or provide information during your stay
- Your devices, such as when you visit our websites or use our mobile apps
- Others who stay at our hotels and properties or use our services, such as your family or friends, your employer, our corporate customers, and organizers of and participants in events or meetings held at our hotels and properties
- Our affiliates
- Rosewood hotel and property owners
- Vendors who provide services on our behalf
- Our business partners, such as travel-related service partners (for example, online booking services, travel agencies, airlines) and other parties who sell products and services under our brand
- Our joint marketing partners
- Online advertising services
- Data analytics providers
- Internet service providers
- Operating systems and platforms
- Social networks
- Recruiting and talent agencies
- Job references, such as your employers or teachers
- Data brokers, such as public databases and background check services
Sale or Sharing of Personal Information
We do not sell your personal information in exchange for monetary compensation. We may share your personal information by allowing certain third parties (such as online advertising services) to collect personal information via automated technologies on our websites and apps for cross-context behavioral advertising purposes. This kind of sharing may be considered a “sale” under California law when the personal information is exchanged for non-monetary consideration. You have the right to opt out of these types of disclosures of your information.
We may sell or share for cross-context behavioral advertising purposes (and may have sold or shared during the 12-month period prior to the effective date of this California Consumer Privacy Statement) the following categories of personal information about you to online advertising services:
- Identifiers
- Commercial Information
- Online Activity
- Inferences
You have the right to opt-out of this disclosure of your information, as detailed below. We do not have actual knowledge that we sell or share the personal information of minors under 16 years of age.
Disclosure of Personal Information
During the 12-month period prior to the effective date of this California Consumer Privacy Statement, we may have disclosed the following categories of personal information about you for a business purpose to the following categories of third parties:
Category of Personal Information
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Categories of Third Parties
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Identifiers
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- Our affiliates
- Hotel and property owners
- Travel companions and others who stay at our hotels or properties or use our services
- Vendors who provide services on our behalf
- Professional services organizations, such as auditors and law firms
- Our business partners, such as travel agencies
- Our joint-marketing partners
- Online advertising services
- Data analytics providers
- Internet service providers
- Operating systems and platforms
- Social networks
- Data brokers, such as background check services
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| Additional Data Subject to Cal. Civ. Code § 1798.80 |
- Our affiliates
- Hotel and property owners
- Travel companions and others who stay at our hotels or properties or use our services
- Vendors who provide services on our behalf
- Professional services organizations
- Our business and joint-marketing partners
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Protected Classifications
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- Our affiliates
- Hotel and property owners
- Vendors who provide services on our behalf
- Professional services organizations
- Our business and joint-marketing partners
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Commercial Information
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- Our affiliates
- Hotel and property owners
- Vendors who provide services on our behalf
- Professional services organizations
- Our business and joint-marketing partners
- Online advertising services
- Data analytics providers
- Social networks
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Online Activity
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- Our affiliates
- Hotel and property owners
- Vendors who provide services on our behalf
- Professional services organizations
- Our business and joint-marketing partners
- Online advertising services
- Data analytics providers
- Internet service providers
- Operating systems and platforms
- Social networks
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Sensory Information
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- Our affiliates
- Hotel and property owners
- Vendors who provide services on our behalf
- Professional services organizations
- Our business and joint-marketing partners
- Data analytics providers
- Internet service providers
- Operating systems and platforms
- Social networks
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Employment Information
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- Our affiliates
- Hotel and property owners
- Travel companions and others who stay at our hotels or properties or use our services
- Vendors who provide services on our behalf
- Professional services organizations
- Data analytics providers
- Data brokers, such as background check services
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Education Information
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- Our affiliates
- Hotel and property owners
- Vendors who provide services on our behalf
- Professional services organizations
- Data analytics providers
- Data brokers, such as background check services
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Inferences
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- Our affiliates
- Hotel and property owners
- Vendors who provide services on our behalf
- Professional services organizations
- Our business and joint-marketing partners
- Online advertising services
- Data analytics providers
- Social networks
- Data brokers, such as background check services
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In addition to the categories of third parties identified above, during the 12-month period prior to the effective date of this California Consumer Privacy Statement, we may have disclosed personal information about you to government entities and third parties in connection with corporate transactions, such as mergers, acquisitions or divestitures.
California Consumer Privacy Rights
You have certain choices regarding your personal information, as described below.
- Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed, and sold about you during the past 12 months.
- Correction: You have the right to request that we correct the personal information we maintain about you, if that information is inaccurate.
- Deletion: You have the right to request that we delete certain personal information we have collected from you.
- Opt-Out of Sale or Sharing: You have the right to opt-out of the sale of your personal information or the sharing of your personal information for cross-context behavioral advertising purposes.
- Shine the Light Request: You also may have the right to request that we provide you with (a) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (b) the identity of those third parties.
How to Submit a Request. To submit an access, correction or deletion request, click here or call us at 1-866-923-1608. To submit a Shine the Light request, email us at privacy.policy@rosewoodhotelgroup.com or send us your request by postal mail or call us toll free in the U.S. at 1-866-923-1608 . To opt-out of the sale or sharing of your personal information, click here or email us at privacy.policy@rosewoodhotelgroup.com. To submit a request as an authorized agent on behalf of a consumer, please contact privacy.policy@rosewoodhotelgroup.com. For questions or concerns about our privacy policies and practices, please contact us as described in the “How To Contact Us” section of the Rosewood Privacy Policy.
Verifying Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you have a Rosewood account with us, we may verify your identity by requiring you to sign in to your account. If you do not have a Rosewood account with us and you request access to, correction of or deletion of your personal information, we may require you to verify your email address or phone number in our records and/or provide any of the following information: (a) amount spent during last stay; (b) most recent stay, or (c) other information about your stays. In addition, if you do not have a Rosewood account and you ask us to provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.
Additional Information. If you choose to exercise any of your rights under the CCPA, you have the right to not rights by visiting <<Privacy Rights Request>>, where you will find more information on how to submit a request and how do we handle your request.
