Applicant Privacy Notice for Mainland China

Last Updated: 25 November 2022

Thank you for your interest in our Company. Rosewood Hotel Group and its affiliates (collectively, “Rosewood”, “we”, “our,” or “us”) are committed to protecting your Personal Information responsibly and in compliance with applicable privacy and data protection laws. This Applicant Privacy Notice for Mainland China (this “Notice”) applies to the information that Rosewood collects to facilitate your job application and includes your use of our careers website located at www.rosewoodhotels.com/careers. Personal Information submitted elsewhere on our websites (e.g., when making a reservation as a guest or after an applicant is hired), will be used in accordance with our <<Privacy Policy for Mainland China>> and Associate Data Privacy Policy.

This Notice describes the types of Personal Information that Rosewood collects, how we use and share your Personal Information, and the rights available to you. This Notice also describes the measures Rosewood takes to protect the security of the data and how you can contact Rosewood about our data protection practices.

It is important for you to review this Notice before submitting your application and Personal Information to us for consideration for employment, intern or apprenticeship. By submitting your Personal Information and by using the Rosewood Careers Website, your Personal Information will be handled and protected in accordance with this Notice.

This Notice is written in English and may be translated into other languages. In the event of any inconsistency, the English version shall prevail.

This Notice is intended to help you better understand the following:

1. General Information
2. What Personal Information Do We Collect
3. How Do We Collect Your Personal Information?
4. Why Is Personal Information Used?
5. How Long Do We Retain Your Personal Information?
6. When And To Whom Do We Disclose Your Personal Information?
7. Where Is Your Personal Information Stored and Cross-Border Data Transfers
8. Security and Integrity Of Your Data
9. Law Applicable To Your Application
10. What Are Your Rights and How To Exercise Your Rights?
11. Updating Your Personal Information
12. Legal Effect and Changes to this Notice
13. Other Important Provisions
14. Contact Us

1. GENERAL INFORMATION

In some locations around the world, Rosewood manages the day-to-day operations of hotels and other properties and performs recruiting and hiring functions on behalf of an independent third-party owner (an “Owner”). At many of these properties, the Owner may be the actual employer.

By applying for positions at Rosewood Careers Website and accordingly submitting your Personal Information, you may be applying for a position with a company other than Rosewood, i.e., the Owner. When Rosewood collects Personal Information about you in connection with such an application, Rosewood shares your Personal Information with the Owner to facilitate your potential employment. The Owner of the property for which you are applying for a position will act as the controller with respect to your Personal Information and the use of your information by such Owner will be governed by its own privacy practices. Following termination or expiration of our management agreements with an Owner, your Personal Information will stay with such Owner.

In particular properties where Rosewood is the actual employer, the local Rosewood affiliate for which you are applying for a position will act as the controller with respect to your Personal Information. The use of your information will be governed by this Notice.

When you apply for a corporate-level position with Rosewood Hotel Group, Rosewood will act as a controller with respect to your Personal Information and the Personal Information pertaining to your application will not be shared with any Owner. The use of your information will be governed by this Notice.

2. WHAT PERSONAL INFORMATION DO WE COLLECT?

A. Personal Information

“Personal Information” means all kinds of information recorded electronically or by other means relating to an identified or identifiable natural person, excluding information that has been anonymized.

When you apply for a position, Rosewood collects the following Personal Information about you:

Contact Details And Identification Details: This includes your name, physical address, e-mail addresses, phone number. It also includes your national ID number or work permits to work in the jurisdictions for which you applied; as well as your photo or image;
Education And Skill Details: This includes your resume, CV, cover letter; educational background, job qualifications, professional and other work-related licenses and certifications; and language skills and proficiency;
Interest In Rosewood: This includes the position for which you would like to submit an application, details of how you heard about the position for which you are applying; your willingness to travel and/or relocate; any information relating to any previous applications you may have submitted to Rosewood or your current/prior work experience with Rosewood;
Third-Party Personal Information: This includes the name and contact details of your recruiter (if any); your third–party employment references or referrals;
Other Information You Choose To Provide To Rosewood: Rosewood and/or other third parties acting on our behalf (e.g., to facilitate the Rosewood Careers Website) may receive data from you whenever you elect to provide other information.
Background Checks: If you are extended an offer, you may be asked questions about your willingness to submit to a background or criminal record check and/or medical examination as permitted by applicable law. Information about you also may be collected from third parties and/ or consumer reporting agencies, for example, in connection with a background check or employment confirmation, and/or employment references, where permitted by applicable law. (See Section ‎14 “Contact Us” below to contact us to learn more about Rosewood’s background checks policies.)

If you provide us with the Personal Information of a reference or any other individual as part of your application, it is your responsibility to obtain consent from that individual prior to providing the information to us.

B. Sensitive Personal Information

We generally do not require what is considered sensitive personal information under China’s Personal Information Protection Law (herein referred to as “Sensitive Personal Information”). Sensitive Personal Information refers to Personal Information that is likely to result in damage to the personal dignity of any natural person or damage to his or her personal or property safety once disclosed or illegally used, including such information as biometric identification, religious belief, specific identity, medical health, financial account and whereabouts and tracks, as well as the Personal Information of minors under the age of fourteen.

Unless otherwise expressly requested, you are not required to submit this type of data as part of your online resume and application submission. If you decide to transmit this type of data to us during the application process, we reserve the right to delete such information from our databases.

See Section 14 “Contact Us” on how to contact us for more information.

Please note that during the application process, you may be asked about your willingness to complete a drug screen or medical examination or other background check in accordance with the position for which you may have applied. Any Sensitive Personal Information derived from such examinations are only processed with your prior separate consent.

3. HOW DO WE COLLECT YOUR PERSONAL INFORMATION?

Information You Provide To Us

Rosewood may collect the Personal Information described above when you apply online use our Website or provide to us in any other way. This includes the Personal Information described above when you apply for a position in the following ways:

Online. When you apply online using the Rosewood Careers Website;
By Email. When you send your Contact Details and Identification Details and Education and Skill Details (including your resume, CV, job application and other information) directly to a Rosewood hotel or Rosewood-managed property via email;
In Person. When you send your application in-person directly with a Rosewood hotel or Rosewood-managed property.
Using Social Media. When you apply for a specific job opening using your WeChat social media profile, certain Personal Information is shared with us consistent with your settings within the social media service, including your Contact Details and Identification Details and Education and Skill Details, and other information you make available on your profile.

The information we collect directly from you includes your Contact Details and Identification Details, Education and Skill Details, Interest in Rosewood, Third-Party Personal Information, Other Information You Choose to Provide to Rosewood, and, should we extend an offer to you, Background Checks.

Information We Collect From Others

Rosewood may collect your Personal Information from others including from recruiters or referrals.

The information we collect may include Contact Details and Identification Details, Education and Skill Details, Third-Party Personal Information and other information such recruiters and third-party referrals choose to provide us.

Voluntary Disclosure

Your provision of Personal Information in connection with job application is generally voluntary. If the collection of any of your Personal Information is mandatory – for example, to complete an application on the Rosewood Careers Website – we will let you know this before we collect it, as well as the consequences of failing to provide us with this information (if any).

Please note that if you decide not to provide information, it may affect the consideration of your employment, unless our receipt of such information is prohibited by applicable law.

4. WHY IS PERSONAL INFORMATION USED

Rosewood needs to process the Personal Information described above (including your Contact Details and Identification Details, Education and Skill Details, and Third-Party Personal Information) in order to potentially enter into an employment contract or relationship with you. This includes for the following business purposes:

Process your application for employment (for Rosewood-managed properties, to communicate with Owners regarding qualified candidates for employment);
Communicate with you;
Provide you with services and respond to your inquiries, including on the Rosewood Careers Website;
Assess your qualifications for a particular position (including to interview, screen, and evaluate you);
Verify your identity and employment eligibility; and
Verify employment references and referrals.

Rosewood also processes the Personal Information described above where it is legally obligated (if applicable). For example:

To manage record-keeping and reporting obligations in connection with its applicant pool; and
To comply with applicant law and regulations.
Rosewood also processes the Personal Information described above based on your consent. For example: If you are offered a position, to conduct criminal, medical and credit background checks (if and to the extent necessary with respect to the respective function of the position applied for).

5. HOW LONG DO WE RETAIN YOUR PERSONAL INFORMATION?

We retain Personal Information for the period necessary to fulfill the purposes outlined in this Notice, based on customary human resource practices and in accordance with applicable legal and regulatory requirements.

If you are selected for a position, your Personal Information will, at a minimum, be retained during the term of your employment, and such retention may be further extended by the applicable statute of limitation and applicable statutory data retention obligations, as the case may be.

Even if you are not selected for the position for which you applied or if you did not apply for a specific position, we may⸺with your consent⸺ retain your Personal Information in order to consider whether your skills are suitable for other job opportunities, in which case we would invite you to apply. Otherwise, your Personal Information will only be retained during the applicable statute of limitation and in order to comply with applicable statutory data retention obligations, as the case may be.

See Section ‎14 “Contact Us” below to contact us to learn more about our retention policies, to withdraw your application for employment and/or your consent for continued retention of your Personal Information after the end of the recruitment process, and to request us to purge your Personal Information. Please note that applicable law may require that we retain your resume or CV for a specific period, even if you request that we do not consider your candidacy for employment.

6. WHEN AND TO WHOM DO WE DISCLOSE YOUR PERSONAL INFORMATION?

6.1 Entrusted Processing. Like most international hotel brands, we may outsource the processing of certain functions and/or information to third parties, and thus select service providers (such as third parties assisting Rosewood with the recruiting operations, such as operation of the Rosewood Careers Website and application tracking system) may process your Personal Information on our behalf. When we do outsource the processing of your Personal Information to third parties or provide your Personal Information to third-party services providers, we will require those third parties to process your Personal Information in accordance with applicable laws and regulations as well as our instructions such as this Notice.

6.2 Sharing of Personal Information. Rosewood will only grant access to Personal Information to specific persons on a need-to-know basis. We may disclose or share your Personal Information described as follows:

Authorized personnel responsible for job openings. Recruiters, managers or their designees, HR personnel, and IT staff may be required to manage the Rosewood Careers Website. Some of these people may be located in different jurisdictions, and as such, your Personal Information may be shared or accessible globally. Rosewood has provided these authorized personnel with categories of Personal Information such as your Contact Details and Identification Details, Education and Skill Details, Interest in Rosewood, Third-Party Personal Information, Other Information You Choose to Provide to Rosewood and Background Checks.
Other third parties such as recruiters, references or referrals, agencies that facilitate background checks, or consultants. We may have to share the Personal Information for the below stated purposes:
- When it is necessary to involve a third-party service provider to facilitate or extend recruitment services, background check processing, and similar services; and
- When explicitly requested by you.

Rosewood has provided these third parties with categories of Personal Information such as your Contact Details and Identification Details, Education and Skill Details, Interest in Rosewood, Third-Party Personal Information, Other Information You Choose to Provide to Rosewood, and Background Checks.

Relevant Rosewood property personnel or Owners. Where Rosewood performs hiring services for Owners, your Personal Information will be shared with Owners for purposes of facilitating your employment contract or employment relationship. If a management agreement expires or is terminated, your Personal Information will remain with the applicable Owner. Your Personal Information will also be transferred to an Owner should you agreed to be transferred and work at such Owner’s property.

Rosewood has provided these property personnel or Owners with categories of Personal Information such as your Contact Details and Identification Details, Education and Skill Details, Interest in Rosewood, Third-Party Personal Information, Other Information You Choose to Provide to Rosewood, and Background Checks.

Government, law enforcement authorities and/or related business consultants in business transfer. We may have to share your Personal Information for the below stated purposes:
- As required by a court order or any other legal or regulatory requirement, including in response to requests from public and government authorities outside your country of residence;
- As required in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business assets (e.g., in connection with any bankruptcy proceeding). Under such circumstances, we will ask the new company or organization holding your Personal Information to continue to process your Personal Information in accordance with this Notice. If the new company or organization needs to use your Personal Information for purposes not stated in this Notice, they will obtain your consent in accordance with the applicable laws and regulations;
- To protect our operations or those of any of our affiliates;
- To protect our rights, privacy, safety or property, or that of our affiliates, you or others; and
- To comply with or in accordance with applicable law.

Rosewood has provided these third parties with categories of Personal Information including your Contact Details and Identification Details, Education and Skill Details, Interest in Rosewood, Third-Party Personal Information, Other Information You Choose to Provide to Rosewood, and Background Checks.

Prior to sharing, we will separately inform you of the names of the receiving parties, their contact information, the purpose and manner of processing and the types of Personal Information, and obtain your consent when required and in accordance with the applicable laws and regulations.

7. WHERE IS YOUR PERSONAL INFORMATION STORED AND CROSS-BORDER DATA TRANSFERS

Due to the global nature of Rosewood’s business, Rosewood may also share your Personal Information with other Rosewood-managed properties and group companies in order to fulfill the purposes described in this Notice.

Rosewood may transfer your Personal Information from the Mainland China to countries or regions outside Mainland China in accordance with the applicable laws and regulations in Mainland China.

If we transfer your Personal Information outside Mainland China, we will fulfil the procedures specified in the relevant laws and regulations and protect your Personal Information with standards no lower than those required by the applicable laws and regulations in Mainland China. The transfers of data to third-party providers are secured by implementing the safeguards required under the applicable data protection law (including contractual arrangements entered into with a third-party vendor). Third-party service providers are expected to protect the confidentiality and security of Personal Information, and only use Personal Information for the provision of services to Rosewood, and in compliance with applicable law.

Contact Rosewood (see Section ‎‎14 “Contact Us” below) to obtain a redacted copy of the Clauses or relevant data transfer agreements (excluding commercial terms).

8. SECURITY AND INTEGRITY OF YOUR DATA

Rosewood maintains appropriate physical, procedural, administrative, organizational and technical security measures intended to prevent loss, misuse, unauthorized access, disclosure, or modification of your Personal Information under Rosewood’s control. To comply with data protection laws and our internal policies, we address information security at all appropriate technology infrastructure points.

While we endeavor to protect the security and integrity of the Personal Information we collect, we cannot guarantee or warrant that any information, during transmission through the Internet or while stored on our system or otherwise in our care, is 100% secure from intrusion by others. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us in accordance with Section ‎14 “Contact Us” below.

It is your sole responsibility to use the appropriate level of care whenever you communicate with us. Do not send sensitive information to us via email.

9. LAW APPLICABLE TO YOUR APPLICATION

The Rosewood Careers Website allows you to benefit from Rosewood’s centralized global recruitment function, while applying for jobs world-wide. The Rosewood Careers Website is operated by different Rosewood affiliates or Rosewood-managed properties, depending upon the location of the specific job for which you apply. Accordingly, the Personal Information you submit to the Rosewood Careers Website is subject to not only the applicable laws in China , but also any local laws that apply to such Rosewood affiliate or Rosewood-managed property.

If we share your Personal Information with an affiliate or Rosewood-managed hotel property located in the country or region in which you are applying for a position, then the applicable entity will handle your Personal Information in accordance with this Notice, or the Owner’s own privacy practices. Any hiring or other employment-related decisions will be made by the hiring affiliate or property in accordance with the laws of the country or region where the job will be located.

10. WHAT ARE YOUR RIGHTS AND HOW TO EXERCISE YOUR RIGHTS

You are conferred by the applicable laws and regulations in Mainland China with the following rights:

Right of access. You are entitled to a copy of the Personal Information we hold about you and to learn details about how we process it. We may require you to prove your identity before providing the requested information.
Right to rectification. We take reasonable steps to ensure that the information we hold about you is accurate and complete. However, if you believe this is not the case, you have the right to request that any incomplete or inaccurate Personal Information that we process about you is amended.
Right to deletion. You have the right to ask us to delete your Personal Information, for example where the Personal Information we collected is no longer necessary for the original purpose, where the Personal Information has become obsolete or where you withdraw your consent (if we are processing your Personal Information based on your consent). However, this will need to be balanced against other factors. For example, we may not be able to comply with your request due to certain legal or regulatory obligations.
Right to restriction of processing. You are entitled to ask us to stop using your Personal Information.
Right to data portability. You have the right to ask us to transfer your Personal Information that you have provided to us to a third party of your choice. This right can only be exercised in certain circumstances as provided by the applicable laws and regulations in Mainland China.
Rights relating to automated decision-making. You have the right not to be subjected to automated decision-making, including profiling, which produces legal effect for you or has a similar significant effect. If you believe you have been subject to an automated decision and do not agree with the outcome, you can ask us to explain, and you also have the right to refuse the decisions made only through automated decision-making methods.
Right to withdraw consent. We may ask for your consent to process your Personal Information in specific cases. When we do this, you have the right to withdraw your consent at any time. We will stop the further processing as soon as possible after the withdrawal of your consent. However, this does not affect the lawfulness of the processing before your consent was withdrawn.

We will respond to your requests of exercising your data subject rights in accordance with the applicable laws and regulations in Mainland China. To the extent as permitted by such laws and regulations, we may not be able to respond to your request of exercising your rights in the following circumstances:

If your request is contrary to our obligations under laws and regulations;
If the requested data is directly related to national security or national defense security;
If the requested data is directly related to public safety, public health, or significant public interest;
If the requested data is directly related to criminal investigations, prosecutions, trials and enforcement of judgments, etc.;
If we have sufficient evidence of your subjective malice or abuse of rights;
If it is in the interest of safeguarding your or other individuals' significant legitimate rights and interests, such as life and property, but it is difficult to obtain your authorization or consent;
If responding to your request to exercise your rights would result in serious harm to your or other individuals' or organizations' lawful interests;
If the requested data involves trade secrets.

How to Exercise Your Rights

If you would like to exercise your rights or learn more about the processing of your Personal Information, please contact us under Section ‎‎14 “Contact Us”. Rosewood will respond to your request(s) as soon as reasonably practicable, but in any case, within the legally required period of time.

(1) Verification Process

Your privacy and information security are important to us. For this reason, we verify your identity or authority to make the request and confirm the Personal Information relates to you, or others, if you are an authorized agent. Accordingly, Rosewood will collect your name, e-mail address and phone number to verify your identity. Upon receiving your request, we also contact you via email and/or other secured communication channel to verify your identity by asking you additional security questions in order to match to your identity with the data we maintain about you.

Please note that, if we cannot verify your identity, we are not obligated to provide you or your Authorized Agent information regarding your Personal Information.

(2) For Your Security

Rosewood does not collect sensitive information, such as your full credit card details, social security or national identification number, to verify your identity. Please do not send Rosewood sensitive information and be aware of any phishing scams or fraudulent calls requesting such information from you.

While we maintain commercially reasonable safeguards to protect your Personal Information, no method of transmission is 100% secure and we do not guarantee or warrant that your Personal Information is under absolute security with the existing security technology.

(3) Submitting Request via a Third Party

You may also exercise your rights via an authorized agent (“Authorized Agent”).

An Authorized Agent can be a third party that you authorize to act on your behalf, such as a third party with power of attorney.

When an Authorized Agent is submitting a request on your behalf, we will require such Authorized Agent to provide evidence of their entitlement, e.g., a written permission, declaration or affidavit demonstrating that they have authority to make the request on your behalf, and the Authorized Agent would have to verify their own identity directly with us.

(4) Disclosure of Personal Information

Once we have verified you or your authorized agent’s identity, we will disclose the specific pieces of Personal Information we collected about you, which will be made in writing and delivered through your account with us, if you maintain such an account. If you do not deletemaintain an account with Rosewood, we will provide such information by mail or electronically, at your option, in a readily useable format that allows you to more readily transmit the information from one entity to another entity.

11. UPDATING YOUR PERSONAL INFORMATION

Rosewood strives to maintain your Personal Information in a manner that is accurate, complete and up to date. However, you have an obligation to keep your Personal Information up to date and inform Rosewood of any significant changes to your Personal Information. Please contact us (Section ‎‎14 “Contact Us” below) if there are any changes in your Personal Information.

12. LEGAL EFFECT AND CHANGES TO THIS NOTICE

This Notice is not, nor is it intended to be, a contract, nor does it otherwise create any legal rights or obligations. Accordingly, Rosewood, in its sole and absolute discretion, may amend, interpret, modify or withdraw any portion of this and related practices with or without Notice, and in accordance with applicable law. Any change in this Notice will apply to all Personal Information in Rosewood’s possession regardless of whether such Personal Information was obtained before or after any such Notice change. If you need clarification regarding any aspect of this Notice, please contact us as provided for in Section ‎‎14 “Contact Us” below.

13. OTHER IMPORTANT PROVISIONS

Use of Rosewood Careers Website by Minors. Except where permitted by local law, the Rosewood Careers Website is not intended for individuals under the age of 18.

Rosewood’s Commitment to Diversity. Cultivating a diverse and inclusive work environment is crucial to success. We encourage applicants from all cultures, races, colors, religions, sexes, national or regional origins, ages, disability status, sexual orientation, gender identity, military, protected veteran status or other status protected by law. Rosewood is an equal opportunity employer.

14. CONTACT US

If you have any questions or comments about our privacy practices or this Notice, or to exercise your rights with respect to your Personal Data (as applicable), you may:

Email us at privacy.policy@rosewoodhotelgroup.com
Calls us toll free in the U.S. at 1-866-923-1608
Write to us at either

Rosewood Hotel Group
2909 Cole Ave, Ste. 303,
Dallas, TX 75204, U.S.
Attn: Legal Department

Rosewood Hotel Group
21/F K11 Atelier. 728 King’s Road,
Quarry Bay, Hong Kong SAR
Attn: Legal Department

You may also submit a request to exercise your 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.

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Rosewood Hotels & Resorts

Applicant Privacy Notice for Mainland China