Privacy Policy for Mainland China

Last Updated: 15 December 2022

Rosewood Hotel Group and its affiliates (collectively, “Rosewood”, “we”, “our” or “us”) are committed to safeguarding your privacy and want you to be familiar with how we collect, disclose and otherwise use information about you. References in this Privacy Policy for Mainland China (“Privacy Policy”) to “Rosewood,” “we,” “our” or “us” are references to the entity responsible for the processing of your Personal Information, which generally is the entity that obtains your Personal Information in the respective case.

This Privacy Policy describes:

our practices in connection with the information we collect from you when you visit our websites that link to this Privacy Policy (the “Site”), or when you use any applications made available by us on or through computers and mobile devices (the “Apps”),
when we communicate with you through e-mail messages that link to this Privacy Policy (collectively, including the Site and Apps, referred to as the “Services”);
our privacy practices when we communicate with you by offline channels, such as when you provide your information to our call centers, or in person (“Offline Services”); and
the basis on which we will process Personal Information we collect from you or that you provide to us, and your choices with respect to that data.

This Privacy Policy excludes those websites and online services that have separate privacy policies and do not incorporate this Privacy Policy by reference or otherwise. This Privacy Policy also does not apply to the collection and processing of Personal Information by the owners of hotels who are third parties not belonging to the Rosewood Hotel Group and its affiliates. For example, third-party owners of hotels may use e-mail or other methods of marketing communication to contact their guests and they are solely responsible for these communications. Please see the hotel owner’s own privacy notice to understand how it will treat your information. Different privacy policies also may apply to other parts of our web presence – for example, web pages for online recruitment.

In certain hotels, Rosewood will provide you with a Guest Privacy Notice (“Notice”) in addition to this Privacy Policy which sets out specifics of the data collection and processing for the hotel and forms together with this Privacy Policy the basis upon which your Personal Information will be processed by Rosewood.

Our privacy practices may be more or less limited in certain countries in which we operate to reflect local practices and legal requirements. We will specifically inform you, if this is the case.

Please read this Privacy Policy carefully. By providing your Personal Information and other information through our Services, you acknowledge that your Personal Information will be processed pursuant to the terms of this Privacy Policy. If any term in this Privacy Policy is unacceptable to you, please do not use the Services or provide any Personal Information.

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

1. What Information Does Rosewood Collect?
2. When and for What Purposes is Your Personal Information Collected?
3. Why is Personal Information Used?
4. When and to Whom Do We Disclose Your Personal Information?
5. What Cookies and Other Technologies Do We Collect?
6. How Do We Protect Your Personal Information?
7. Third-Party Websites and Services
8. Where is Your Personal Information Stored and Cross-Border Data Transfers
9. How Long Do We Retain Your Personal Information?
10. How Can You Manage Your Preferences and Information?
11. What Are Your Rights and How To Exercise Your Rights?
12. What Information is Collected From Minors under 16?
13. What About Privacy Policy Modifications?
14. How to Contact Us?

1. WHAT INFORMATION DOES ROSEWOOD COLLECT?

1.1 Personal Information from or about You

The term “Personal Information” as used in this Privacy Policy refers to 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 contact us, book as a guest, visit one of our hotels or properties, or use our Site, we collect certain Personal Information from you. We have collected categories of Personal Information such as:

Contact Details: Your name, e-mail address, phone number, physical address (billing and shipping), company affiliation, title;
Demographic Data: Demographic information and location data, and government-issued identifiers (e.g., drivers’ license (including dates of birth), passport numbers or other national identifiers);
Financial Details: Your credit card and/or debit card details;
Guest Stay Information: Guest stay information, special requests and preferences (including preferred room type or floor, spend, vacation preferences, amenities requested, language preferences, interests, hobbies, ages of children or companions and any other aspects of the Services used), telephone numbers dialed, faxes and telephone messages received;
Log Details: IP addresses, online user account details or profiles when you log-in to your Rosewood account;
Frequent Flyer Details: Frequent flyer and travel partner program affiliations and member number; hotel, airline and rental car packages booked;
Social Media Details: Social media account information, profile pictures or posts;
Your Feedback: Information, feedback or content you provide regarding your marketing preferences, in surveys, comment cards, sweepstakes, or promotional offers on our Services and those of third parties;
CCTV/Surveillance: For your safety and security, images and visual recordings through the use of closed circuit television systems collected while visiting a Rosewood hotel or property, where permitted by applicable law;
Call Recordings: Conversations, including records or monitoring of guest service calls for quality assurance and training purposes, and other communications such as in-app messages or SMS text messages, where permitted by applicable law or based upon consent;
Corporate Account Data: Contact details concerning the employees of corporate accounts and vendors and other individuals with whom we do business (e.g., travel agents, bookers, event planners); and
Other Data: Other types of information that you voluntarily choose to provide to us.

1.2 Sensitive Personal Information

From time to time, you may provide or we may collect “Sensitive Personal Information” which 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. For example, you may disclose your religious affiliation to us when you host or attend an event at one of our hotels or provide your health information or dietary restrictions so that we can accommodate you during your stay.

We only process Sensitive Personal Information where there are specific purposes and sufficient necessity. Unless otherwise required by applicable law, you are not required to provide us with any of your Sensitive Personal Information. Should you choose not to, your decision would not prevent you from using our Services.

2. WHEN AND FOR WHAT PURPOSES IS YOUR PERSONAL INFORMATION COLLECTED?

We collect Personal Information about you in the manners and for the purposes as listed below:

When you make reservations, stay at a property or plan or attend an event. Visitors who elect to make reservations using our Services or Offline Services will be asked to supply specific Personal Information, including your Contact Details and Demographic Details such as your name, e-mail address and contact information, as well as Financial Information to secure the reservation, such as a credit card number. We collect your Personal Information, and with your consent, Sensitive Personal Information to provide you with services, including when you purchase goods and services, inform us of any requests, or take advantage of services such as concierge services, health clubs and spa treatments, activities, equipment rentals, and child care services. If you plan or host an event with us, we collect meeting and event specifications, such as your name, contact details, date of event, occasion, number of guest rooms required, and length of stay. We also collect information about guests that are a part of your group or event.
When you sign up for promotional offers and sweepstakes. We collect your e-mail address when you sign up for promotional offers, newsletters or sweepstakes.
When you provide your comments and feedback or communicate with us. We may collect Personal Information that you voluntarily share with us in surveys, guest feedback or comment cards, as well as on third-party websites. We also collect your Personal Information when you communicate with us via text or e-mail or otherwise, like WeChat.
When you share photos. We collect and publish photos and images you voluntarily share with us about your experience with us, which you may post on our Services. For more information, please visit Rosewood’s User Generated Content Terms of Use at https://www.rosewoodhotels.com/en/olapic-terms-of-use.
When you purchase a gift card. If you decide to purchase a gift card through rosewoodgiftcard.com, we collect Personal Information including the recipient’s name, e-mail address, shipping information, and any other information you voluntarily provide.
From social media. We collect Social Media Details such as when you ‘like’ the Website, share content or follow us on social media sites like Facebook, Twitter, Pinterest Instagram, or WeChat. If you choose to log-in, connect with or link to Services using your social media account certain Personal Information is shared with us consistent with your settings within the social media service, such as location, check-ins, activities, interests, photos, status updates, as well as Personal Information that may be a part of your profile or friend’s profile.
When you apply for career opportunities. If you choose to apply online with us, how we process your Personal Information is further described in the <<Applicant Privacy Notice>>, not in this Privacy Policy.
When you inquire about development or Owner opportunities. We may collect your Personal Information including your e-mail address when you contact us to learn more about development or ownership opportunities with us.

We collect Personal Information, including from other sources. This includes:

From Other Rosewood Hotel and Properties. The Personal Information you provide to us in connection with making a reservation, including your Contact Details, Demographic Data, Financial and Guest Stay Information, is shared and received with and from other Rosewood hotels and properties you have previously visited for purposes of meeting your reservation requests and preferences in advance.
From Affiliates. We are a global enterprise and may receive your Personal Information from other companies or hotels within our group, including in our offices in Hong Kong, the European Economic Area (EEA) and the United States in order to help render services to you associated with your stay at our hotels or other properties and with your Contact Details to provide you marketing communications, consistent with your choices. For a complete listing of our affiliates, please contact us as indicated in Section 14 or see www.rosewoodhotelgroup.com.
From Owners. We manage hotels and other properties on behalf of third-party owners (“Owners”). If you make a reservation to stay at a property managed by us, we will share and receive Personal Information with and from the Owner of that property, e.g., your Contact Details, Guest Stay Information, Financial Details, Your Feedback and any observations about your service preferences. Owners’ use of your Personal Information will be governed by their own privacy practices and is only covered in this Privacy Policy where specifically noted.
From Your Travel Companion. We may collect Personal Information related to you from your travel companion. Children’s Personal Information may be collected through their parent or guardian. If you are the party submitting Personal Information relating to other people in connection with the Services, you represent that you have the authority to do so and permit us to use their Personal Information for the purposes described in this Privacy Policy.
From Other Sources. We may receive your Personal Information from other sources, like public databases, joint marketing partners, social media sites that consisting with your settings on related services, and other third parties including online booking services, travel agencies, airline, credit card partners and other parties who sell products and services under our brand. Such information usually includes your Contact Details, Social Media Details, Your Feedback and Other Data that you voluntarily choose to provide to us.

3. WHY IS PERSONAL INFORMATION USED?

We use your Personal Information, both for business and commercial purposes as set forth below.

3.1 Performance of a Contract. We process your Personal Information in order to perform a contract with you, including to complete your reservation, provide you goods and services that you requested, or to inform Owners of your stay in order to render services to you while visiting a hotel or other property that we manage.

3.2 To Comply with Legal Obligations. We process your Personal Information where it is necessary to comply with legal obligations to which it may be bound. This includes keeping our Services safe and secure, detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, debugging and repairing errors, verifying customer information complying with legal processes, responding to requests from public and government authorities around the world, and pursuing available remedies or limit damage we or other third parties may sustain.

3.3 With Your Consent. We process your Personal Information when we have your valid consent to do you, including to providing you with superior customer service and a personalized experience when staying with us, protecting our operations or those of any of our affiliates or other third parties, distributing and responding to surveys regarding your experience, allowing you to participate in sweepstakes, contests, and other promotions and to administer these activities (please bear in mind that some of these promotions have additional rules, which could contain additional information regarding what Personal Information we collect and how it is used, and we encourage you to read these rules carefully), communicate (including by e-mail and SMS) with you during your stay, to send you promotional offers, newsletters, information on us, our Services, and other marketing communications in accordance with your preferences, providing you with information that you have requested and responding to your inquiries, and to process Sensitive Personal Information you may have provided us in connection with your stay; for example, any dietary restrictions or special accommodations for physical and medical conditions. Such circumstances also include, subject to applicable law and regulations, processing your Personal Information in the event of a corporate event such as a sale, merger or change in control.

3.4 In An Emergency. In certain circumstances when it is not possible to obtain your consent, it may be necessary for us to process your Personal Information, including Sensitive Personal Information you provided through our Services, where it is necessary to respond to public health emergencies or to protect the life, health and property safety of natural persons in emergency situations, for example in the event of a medical emergency.

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

4.1 Entrusted Processing. Like most international hotel brands, we may outsource the processing of certain functions and/or information to third parties, and thus our group entities (for a complete listing of our affiliates, please contact us as indicated in Section 14 or see www.rosewoodhotelgroup.com), hotels and residences managed and operated by us, third-party service providers (such as providers of services hosting, data analysis, payment and credit card processing, order fulfilment, customer service, e-mail delivery, financial services companies, delivery services, advertising networks, and information technology, providers of services such as spa treatment, salons, and restaurants within our hotels or other properties, or event planners or organizers of any event you plan or host with us, and other third party suppliers and/or services providers to assist us to operate effectively and provide you with the best experiences with our services), and our partners, consultants and advisors (including financial institutions, external auditors, lawyers, and credit card issuers) 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 Privacy Policy.

4.2 Sharing of Personal Information. We may disclose or share your Personal Information described as follows:

To Owners, Hotels and Other Properties. The Personal Information you provide to us in connection with making a reservation, including your Contact Details, Demographic Data, Financial Details, and Guest Stay Information, is shared with the respective Owner and hotel or property for purposes of meeting your reservation request. After your stay, we retain your Personal Information, including the details of your stay and your preferences (e.g., room, type, interest, hobbies, amenities used) to provide you personalized service during your next stay, subject to your preferences.

You can object to the retention of your Personal Information for this purpose by contacting us as described in Section 14 of this Privacy Policy.

Travel-Related Service Partners. We may share your Personal Information with select third parties, including your Contact Details, Demographic Data, Financial Details, Frequent Flyer Details, and Guest Stay Information. For example, we may help arrange rental cars and share Personal Information with them in order to provide those services. We also may work with third parties, such as travel agencies and airlines to help provide you with a single source for purchasing travel-related services. This Privacy Policy does not apply to information that you provide directly to third partes.
E-Folio Program. If you are an employee or corporate client of a company that participates in Rosewood’s E-Folio Program, a summary of the goods and services provided to you during your stay will be shared with the payment card provider, who in turn, may share that summary with your employer or corporate client. Once the Personal Information, including your Corporate Account Data, is transferred to the credit card issuer, credit card network operator, your employer and/or corporate client, it is no longer subject to the provisions of this Privacy Policy. Please visit the privacy policies of your employer or corporate client, the relevant payment card provider and card issuer for more information on their data privacy and protection practices.
Co-Sponsors of Promotions and Sweepstakes. Your Personal Information, including your Contact Details or Feedback, may be shared with our affiliates or other unaffiliated business partners that serve as co-sponsors or third-party sponsors of promotions, sweepstakes, or other contests if you enter into one of these activities on our Services. Such co-sponsors may be the join Personal Information handler for the processing of your Personal Information with us sometimes, and under such circumstances, we will inform you about this when required by the applicable laws and regulations.
Business Transfers. From time to time, we may sell our business, hotels and other assets or may cease managing a hotel or property owned by an Owner. In those circumstances, we may include Personal Information collected about you, or control of that Personal Information, as a business asset in any such transfer. For example, if we cease to operate a hotel property we do not own, the Owner may continue to have and use your Personal Information for continued business purposes consistent with the hotel’s operations, including direct marketing. Additionally, we may disclose your Personal Information to a buyer or other successor in the event of a merger, sale or other transfer event, in which Personal Information held by us about our users is among the assets transferred. We will ask the new company or organization holding your Personal Information to continue to process your Personal Information in accordance with this Privacy Policy. If the new company or organization needs to use your Personal Information for purposes not stated in this Privacy Policy, they will obtain your consent in accordance with the applicable laws and regulations.
Legal Obligation. If we are under a duty to disclose or share your Personal Information in order to comply with any legal obligation, pursuant to a legal request, subpoena or other legal processes, or in order to enforce or apply our Terms of Use and other agreements, including for billing and collection purposes; or to protect the rights, property, or our safety, our guests, or others. This may include exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

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.

In addition, we may share aggregated data with third parties collectively in an anonymous way, which does not reveal Personal Information.

4.3 Disclosure of Personal Information. In general, we do not disclose your Personal Information. Having said that, if you connect to one of our social media pages, we may disclose your Personal Information including your Social Media Details to your friends associated with your social media account, to other website users, and to your social media account provider, in connection with your social sharing activities. We may make reviews, message boards, blogs and other user-generated content available to users on our Services. Any information disclosed in these areas is public information and you should accordingly exercise caution when deciding to disclose your Personal Information in this context. We are not responsible for the privacy practices of other users including web operators to whom you provide your Personal Information.

4.4 Third-party SDK. To provide and optimize our services, third-party SDKs are embedded in our applications. The following lists the names of the third-party SDKs we currently embed, the types of Personal Information collected, and the purpose of collection and use. If you have questions about the collection of your Personal Information by the third parties through the SDKs, please refer to the privacy policies of such third parties.

Name of the SDK	Provider of the SDK	Purposes of the SDK	Application where the SDK is embedded	Types of Personal Information collected by the SDK	Link to the privacy policy of the SDK
Gaode LBS	AutoNavi Holding Ltd.	Precise Location, POI Search, Distance Calculation, Point Selection on Map	Shipping address and location input by User/Merchant	When user place order, add address	https://lbs.amap.com/dev/index
Tecent LBS	Tencent Technology (Shenzhen) Co., Ltd.	Precise Location, POI Search, Distance Calculation, Point Selection on Map	Shipping address and location input by User/Merchant	When user place order, add address	https://www.tencent.com/zh-cn/privacy-policy.html
Baidu LBS	Beijing Baidu Netcom Science and Technology Co.,Ltd.	Precise Location, POI Search, Distance Calculation, Point Selection on Map	Shipping address and location input by User/Merchant	When user place order, add address	https://lbsyun.baidu.com/index.php?title=openprivay
Google LBS	Google Inc.	Precise Location, POI Search, Distance Calculation, Point Selection on Map	Store address selected by Merchant	User Authorization	https://developers.google.com/maps/documentation/geocoding/start
Express 100 Express in-transit monitoring	Shenzhen Qianhai Baidi Network Co.,Ltd.	Express Information Query, Express Real-time Tracking, Express Company Query	User's mobile phone number, courier tracking number	When user place order, add address	https://www.kuaidi100.com/about/private.shtml
Kuaidiniao express in-transit monitoring	Shenzhen Kuaijin Data Technology Service Co., Ltd	Express Information Query, Express Real-time Tracking, Express Company Query	User's mobile phone number, courier tracking number	When user place order, add address	http://www.kdniao.com/aboutus-statement
WeChat Logistics Assistant	Tencent Technology (Shenzhen) Co., Ltd.	Express Information Query, Express Real-time Tracking, Express Company Query	User's mobile phone number, courier tracking number	When user place order, add address	http://weixin.qq.com/cgi-bin/readtemplate?lang=zh_CN&t=weixin_agreement&s=privacy
Linqu Paotui &Delivery	Shanghai Linqu Network Technology Co.,Ltd.	Intra-city Logistics Distribution, Logistics Order Information Query, Courier Tracking	User's mobile phone number, delivery address, product information, latitude and longitude information, order information	When user place order	http://tg.linjia.me/
Dada Express	Dada Nexus Limited	Intra-city Logistics Distribution, Logistics Order Information Query, Courier Tracking	User's mobile phone number, delivery address, product information, latitude and longitude information, order information	When user place order	https://www.imdada.cn/
SF Intra-city Delivery	Shenzhen Shunfeng Tongcheng Logistics Co., Ltd.	Intra-city Logistics Distribution, Logistics Order Information Query, Courier Tracking	User's mobile phone number, delivery address, product information, latitude and longitude information, order information	When user place order	https://www.sf-cityrush.com/armor/agreement/3c2fe074-f811-4503-a33c-ce4b88a6ef80.html
Shansong Intra-City Delivery	Beijing Tongcheng Bing Technology Co., Ltd.	Intra-city Logistics Distribution, Logistics Order Information Query, Courier Tracking	User's mobile phone number, delivery address, product information, latitude and longitude information, order information	When user place order	http://m.ishansong.com/v2/activity/miniprogram-privacy.html
Meituan Intra-city Delivery	Beijing Sankuai Online Technology Co., Ltd.	Intra-city Logistics Distribution, Logistics Order Information Query, Courier Tracking	User's mobile phone number, delivery address, product information, latitude and longitude information, order information	When user place order	https://peisong.meituan.com/app/zbRuleDetail?protocolType=3
Fengniao Intra-city Delivery	Alibaba Local Life Service	Intra-city Logistics Distribution, Logistics Order Information Query, Courier Tracking	User's mobile phone number, delivery address, product information, latitude and longitude information, order information	When user place order	https://terms.alicdn.com/legal-agreement/terms/suit_bu1_other/suit_bu1_other201906061426_71208.html
Cathay Pacific Insurance Freight Insurance Service	Cathay Century Insurance Co., Ltd.	Freight insurance, Insurance Claims Service	User's mobile phone number, delivery address, product information, latitude and longitude information, Order information, Logistics information, ID Card information, payment information	When user place order, apply for after-sales service	https://www.cathay-ins.com.cn/

5. WHAT COOKIES AND OTHER TECHNOLOGIES DO WE COLLECT?

5.1 Automatic Data Collection. We may use automatic data collection technologies to collect certain statistical (non-personal) information about your equipment, browsing actions, and patterns, including (a) details of your visits to our Services, including traffic data and location data, date and time of access, frequency and other communication data; (b) information about your computer and internet connection, including your IP address, operating system, host domain, and browser type; and (c) details of referring websites actions, and patterns.

5.2 Cookies. As further described in our <<Cookie Policy>>, we use cookies and other similar technologies (e.g., web beacons, pixels, ad tags and device identifiers) to recognize you and/or your device(s) on or across different Services and devices. We also allow other third parties to use cookies as described in our <<Cookie Policy>> You can control cookies through your browser settings and other tools. For more information on the cookies we collect and how to disable them, please visit our <<Cookie Policy>>.

5.3 Social Media Plug-ins. One of the features of our Site is that it uses what are called social plugins (“plugins”) from the social networks Twitter, Facebook, YouTube, Pinterest, and Instagram. These plugins are indicated by the respective logo of the social network. When you access our Site, your browser establishes a direct connection with the servers of these social networks. The content of the plugin is transferred by the social network directly to your browser, which then integrates it into the Site.

5.3.1 Integration of the plugin causes Facebook, for example, to receive the information that you have loaded the corresponding page of our Site. If you are logged in with Facebook, it will be able to assign your visit to your Facebook account. Please note that an exchange of this information already takes place when you visit our Site, regardless of whether you interact with the plugin or not. If you interact with the plugins, such as by pressing the ‘Like’ button, the corresponding information is sent directly to Facebook by your browser and saved there. You can find information on the purpose and extent of data acquisition as well as how the data is processed further and used by the social networks, together with your rights and optional settings to protect your private sphere, in the data protection notes of the social networks.

5.3.2 If you do not want incorporated social networks to gather data about you via our Site, you must log out on the respective domain of the social network before visiting our Site. If you wish to prevent information being exchanged with the above-mentioned social networks during your visit to our Site, you can opt out of cookies through your browser settings and other tools. For more information, please visit our <<Cookie Policy>>.

5.4 Wi-Fi and Location-Based Services. In the course and for the purpose of providing Wi-Fi services at our hotels and other properties, we may collect device identifiers (such as your IP address, or other unique identifier). Based upon your consent, we also may collect information about the physical location on your device through use of the Wi-Fi services or other technologies to provide you with personalized location-based services, such as to customized offers and promotions or to find a hotel near you.

6. HOW DO WE PROTECT PERSONAL INFORMATION?

We maintain commercially reasonable security safeguards that are designed to protect the Personal Information we collect against unauthorized use, disclosure, alteration or destruction. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure and we cannot guarantee or warrant that your Personal Information is under absolute security with the existing security technology. Additionally, when requesting information or sending information or forms to us by e-mail, please be advised that e-mail communication to and from our Services are not secure unless clearly noted otherwise. This is a risk inherent in the use of e-mail.

7. THIRD-PARTY WEBSITES AND SERVICES

7.1 Our Services may contain links to, or have features that are hosted by, other third-party websites or services that are not owned or controlled by us. For example, we give you the opportunity to connect, link, or share our Services (and the content you access) via certain social media websites.

7.2 This Privacy Policy only addresses the collection, use, and disclosure of information by us through your interaction with our Services. This Privacy Policy does not address the policies or practices of any third parties or any third-party websites or features that are linked to or available from our Services. If you provide any information to any other third parties, different rules regarding the collection and use of your Personal Information by such third parties may apply. Please contact these entities directly if you have any questions about their privacy practices.

7.3 We also may partner with a limited number of Internet providers to offer Internet access to our guests. Your use of on-property Internet service is subject to the third-party Internet provider’s terms of use and privacy policy, which you can access using the links on the service sign-in page, or by visiting the Internet provider’s website.

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

We store your Personal Information within Mainland China. As an international hotel brand, Rosewood may also transfer and store your Personal Information to countries or regions outside Mainland China, and your Personal Information also may be processed by staff operating outside the Mainland China who work for us or other entities acting as parties entrusted by us to processing data on our behalf. This includes staff and providers engaged in, among other things, the fulfillment of your request or order and the provision of support services. More information on to whom your data is disclosed can be found in Section 4.

If we need to 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.

9. HOW LONG DO WE RETAIN YOUR PERSONAL INFORMATION?

We retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by applicable law. Note that we may need to retain certain information for recordkeeping purposes and/or to complete transactions (e.g., when you make a purchase or reservation), and you may not be able to change or delete the Personal Information you provided until after completion of such purchase or reservation.

10. HOW CAN YOU MANAGE YOUR PREFERENCES AND INFORMATION?

10.1 Commercial E-mails. You may opt-out of receiving commercial e-mails from us by following the instructions contained in any of the commercial e-mails. Unsubscribing from one type of communication may not unsubscribe you from another type. Please note that even if you unsubscribe from commercial e-mail messages, we may still e-mail you non-commercial (transactional) e-mails related to your account and your transactions via the Services.

10.2 Owners (following termination or expiration of our management agreements) and third-party providers may use your Personal Information for marketing purposes. If you wish to opt-out of receiving offers directly Owners and third-party providers, you can follow the instructions in the e-mails that they send you.

10.3 Text Messages and SMS. To opt out of text messages, reply STOP to the message you received or contact the hotel or property front desk to inform them you no longer wish to receive text messages.

10.4 Mobile Apps. You can control whether our Apps send you push notifications by change your notification settings on your mobile device.

10.5 Access and Connections to Social Media. If you registered with the Services through your social media account, or connected, linked, or shared your use of our Services via your social media profile, you can manage the permissions granted to such third-party social media services by accessing your user settings under your account. You also can remove our access to your social media account or otherwise control what information these third-party social media services share with us at any time by accessing the privacy settings in your social media account.

11. 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 Chinese laws.
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 right;
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.

If we terminate our services or operations, we will notify you at least thirty (30) days in advance and will delete or anonymize your Personal Information after termination of services or operations.

How to Exercise Your Rights

To exercise the rights described above, contact us as provided for in Section 14 below. Rosewood will respond to your request(s) as soon as reasonably practicable, but in any case, within the legally required period of time.

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.

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.

Submitting Request via an Authorized Agent

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.

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 maintain 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.

12. WHAT INFORMATION IS COLLECTED FROM MINORS UNDER 16?

12.1 We have not designed the Services for, and do not intend for them to be used by, anyone under age 16. We do present information regarding our Rose Buds® program on our Services for the reference of adults that are interested in activities at our locations for their children. Accordingly, the Services should not be used by anyone under age 16 without adult supervision. If you are under 16, please do not provide Personal Information of any kind whatsoever.

12.2 Should we inadvertently acquire Personal Information or other information from users under the age of 16, we will not knowingly provide this data to any third party for any purpose. If a minor under 16 does provide us with Personal Information over Services, a parent or guardian of that minor may contact us and upon notification, we will delete from our records any information collected from minors under the age of 16.

13. WHAT ABOUT PRIVACY POLICY MODIFICATIONS?

We reserve the right to change this Privacy Policy at any time. Any changes we make will be posted on this page. If we make material changes to how we treat your Personal Information, we will notify you through a notice on the Services home page. The date this Privacy Policy was last revised is identified at the top of the page. It is your responsibility to ensure that we have a deliverable e-mail address for you, and for you to periodically monitor and review any updates to this Privacy Policy. Your continued use of our Services after such amendments will be deemed your acknowledgement of these changes to this Privacy Policy.

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

Privacy Policy for Mainland China