Mobile App Privacy Policy

This guest services platform privacy policy (this “Privacy Policy”) in intended to inform you about how Virgin Hotels, LLC, a Delaware limited liability company with an address at 2601 South Bayshore Drive, Suite 340, Miami, FL 33133 (“Virgin Hotels”, “we”, “us”, “our”) collects and uses the personally identifiable information (“PII” or “Personal Information”) and other information of guests staying at one of our hotels (“Guests”) and other Virgin Hotels users (each a “user” and collectively “users”, and when such user specifically refers to you then “you”, “your”, “yours” or “yourself”) of the Virgin Hotels guest services platform (the “Platform”).

The Platform – an Overview

The Platform enables different types of users to utilize different levels of its functionality. For instance, non-Guest visitors to a hotel location who are not required to register with us may have access to the WiFi network functionality of the Platform, whereas Guests who have registered with us, as described in the Platform’s terms & conditions document which can be accessed at “T&C” and who are located within one of our hotel locations, will have access to more robust Platform functionality, including without limitation the ability to access early check-in, order room service, control their room entertainment and temperature systems and to make restaurant and spa reservations. By using the Platform, you consent to the collection and use of your PII and other information by Virgin Hotels as described in this Privacy Policy.

Modification of this Privacy Policy

We reserve the right to change, modify, alter or otherwise update how we handle the information we collect and process through the Platform, and to modify this Privacy Policy, at any time. You agree to review this Privacy Policy periodically to be aware of any such modifications. We will indicate that changes to this Privacy Policy have been made by updating the date indicated after “Last Updated” at the beginning of this Privacy Policy. We will be happy to provide you with prior versions of this Privacy Policy upon your written request to us. If you do not agree to abide by the initial version or any modified version of this Privacy Policy, then you are not authorized to use the Platform. The current version of this Privacy Policy is accessible via the footer of the Platform’s home/landing page.

Virgin Hotels’ Collection and Use Protocols Regarding Personal Information

Virgin Hotels’ primary goal in collecting Personal Information from users is to provide them with a smooth, efficient, and personalized experience in utilizing the Platform. Collecting such information enables Virgin Hotels to provide services and features that are intended to meet users’ needs more quickly and effectively, and to customize the Platform to improve the overall user experiences.

Users who wish to make purchases through the Platform may need to provide Virgin Hotels with certain PII, including without limitation their name and payment information. Users may also need to provide Virgin Hotels with certain other PII for such purposes or in order to use certain other Platform functionality, all as directed by Virgin Hotels. As described further below, Virgin Hotels will also collect and use general statistical, non-PII about users and their interests.

Virgin Hotels will share your PII with the property owners and management companies of our hotels, as well as with the third party technology provider operating the Platform on our behalf. This third party technology provider may also own, manage and service the servers which power the Platform and on which all user PII is stored, and may share all or some of such PII collected through the Platform with each hotel property owner. Virgin Hotels has obligated this third party technology provider and each hotel property owner in writing to keep all PII confidential, except for standard exceptions arising in connection with court orders, law enforcement requests and the like.

We may provide a user’s PII to individuals or entities who work with Virgin Hotels or on Virgin Hotels’ behalf. These individuals or entities may use such user PII to help fulfill a user’s requests and to help Virgin Hotels communicate with such users about different services or resources offered through the Platform. For example, Virgin Hotels may transfer certain PII of a user or other information to service providers and other third parties who assist Virgin Hotels in operating the Platform, and with shipping companies to deliver third party products to users. Virgin Hotels additionally may share a user’s PII with e-commerce providers in order to facilitate the fulfillment of purchases made by users through the Platform. In general, Virgin Hotels may use and disclose a user’s PII to improve and enhance the overall user experience through the Platform and for other purposes.

Virgin Hotels may also release a user’s PII to other third parties if Virgin Hotels believes that such release is necessary to comply with the law (e.g., a legal process or a statutory authorization or requirement) or a court order, to apply or enforce Virgin Hotels’ security protocols, to protect us or users, to protect against the fraudulent, abusive, or unlawful use of the Platform, or if Virgin Hotels reasonably believes that a danger to any person or property requires the disclosure of such PII or otherwise is needed to protect Virgin Hotels’ interests.

Virgin Hotels’ Collection and Use Protocols Regarding Non-Personal Information

Virgin Hotels may also collect anonymous and aggregate information from users about their preferences in navigating the Platform by using cookies, action tags and other methods. Cookies are small text files that identify a user’s computer or mobile device. Virgin Hotels may use cookies to, among other things, to monitor a user’s Platform usage, customize Platform features, identify a user’s computer or mobile device operating system and browser, and to complete transactions. An action tag is a small, graphic image on a webpage that is designed to allow us or third party to monitor who is visiting a website by collecting the IP address of the computer to which the tag is sent, the URL of the webpage that the tag comes from and the time at which such webpage was viewed. Action tags may be associated with cookie information. Virgin Hotels may also use anonymous and aggregate information collected by it for promotional and other business purposes.

Virgin Hotels will automatically track certain non-PII about users based upon their behavior in using the Platform. Virgin Hotels uses this information to conduct internal research on users’ demographics, interests, and behavior so that it can better understand and/or serve users. This information is compiled and analyzed on an aggregated basis. Virgin Hotels may create and maintain a file or activity for users about their current and past activities in using the Platform, so that Virgin Hotels will be better equipped to resolve certain disputes, troubleshoot certain problems and fulfill user requests. At times, Virgin Hotels may analyze the behavior of multiple users collectively to identify problems or resolve disputes, or for security or compliance purposes.

Using Our Chat Functionality

The Platform enables certain users to post public comments to a Virgin Hotels chat areas or message boards viewable by anyone connected to the Platform. Note that all content that you post to this chat area/message board is publicly viewable and may be accessed by any person using the Platform. So if you choose to post content to the Platform, you do so at your sole responsibility and risk. Thus we advise you to think carefully before choosing to post any content to the Platform.

Users May Elect not to be Identified by Virgin Hotels

Users can set their website browsers to warn them before accepting cookies and elect to refuse cookies when their browser alerts them to their presence. In such a case, users can also adjust the settings in their browsers to refuse all cookies. If users do not want Virgin Hotels to have any of their PII, they should not submit any of their PII through the Platform. However, users should keep in mind that if they refuse cookies or refuse to submit certain PII to us, they will not be able to use certain the Platform’s functionality, including without limitation purchasing certain products and/or services through the Platform.

Virgin Hotels’ Policies Regarding the Handling and Storage of Information

Virgin Hotels takes steps consistent with commercially reasonable industry standards to secure user PII collected from loss, misuse, unauthorized access and destruction while under Virgin Hotels’ control. However, please note that despite Virgin Hotels’ efforts to protect such PII and the other information it collects, Virgin Hotels cannot guarantee that such information will not be lost, disclosed or accessed by accidental circumstances or by the unauthorized acts of others.

Virgin Hotel’s Policies Regarding Children Under Age 13

The Platform is intended for general use of persons who have reached the legal age of consent, and it is not targeted to anyone under the age of thirteen (13) years of age. Virgin Hotels does not knowingly collect PII from anyone under thirteen (13) years of age. If Virgin Hotels learns that it has unwittingly collected PII from anyone under thirteen (13) years of age, it will promptly delete such information. Users should immediately notify Virgin Hotels in writing if they learn that any such PII has been provided to Virgin Hotels.

Users May Request the Removal of their Personal Information from Virgin Hotels

Any user may request that Virgin Hotels remove from its databases the PII that such user has submitted to Virgin Hotels through using the Platform. In such a case, a user must specify such a request in writing to Virgin Hotels, by email at apphelp@virginhotels.com. Users may also contact Virgin Hotels if they have questions or concerns about any of our information collection or use practices at apphelp@virginhotels.com.

Our Right of Assignment

Virgin Hotels’ rights under the this Privacy Policy may be automatically assigned by Virgin Hotels, in our sole discretion, to a third party or parties, and such an assignment will inure to the benefit of our successors, assigns and/or licensees.

Links we Provide to Third Party Websites

The Platform contains links to various third party websites. Virgin Hotels does not have any control over third party websites and we take no responsibility for any information you give the operators of such websites or for any relationship between you and such third parties. Other websites have different privacy and security policies, which we advise you to read. Once you visit a third party website, you are subject to the provisions of the privacy policy of such website and not this Privacy Policy.

Accessing your Personal Information

You can request, at any time, access to the Personal Information we hold about you. You can write to us by email at apphelp@virginhotels.com or at the following postal address requesting access to your PII: Virgin Hotels, LLC, Attention: Marketing Department, 2601 South Bayshore Drive, Suite 340, Miami, FL 33133.