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Privacy Policy

Last Updated: August 23, 2017

This Privacy Policy in intended to inform you about how Virgin Hotels, LLC, a Delaware limited liability company with an address at 3390 Mary Street | Suite 218 | Coconut Grove, 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 a user utilizes the Virgin Hotels guest services platform (the “Platform”) and the Virgin Hotels website (the “Website”).
Virgin Hotels views the protection of your privacy as an important responsibility. We are committed to protecting the PII you submit to us through the Website. We have a philosophy about the way we interact with our users. If you hear from us, we will always aim to be respectful, relevant and appropriate. If at any time you don’t feel we’ve lived up to our philosophy, please let us know straight away by getting in touch with us at info@virginhotels.com.
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 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.
The Website – an Overview

The Website enables Website Users to utilize various functionality of the Website, including the ability to purchase products and services through the Website. By using the Website, 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 or the Website, and to modify this Privacy Policy, at any time. Any modified version of this Privacy Policy will be posted to VirginHotels.com to make you aware of changes. 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 or the Website. The current version of this Privacy Policy is accessible via the footer of the Platform’s home/landing page and the footer of the Website home 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 and Website and visiting our Hotels. 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 and Website to improve the overall user experiences.
The PII that Virgin Hotels may collect and store includes the following information:

your name, gender, personal and work contact details, business title, date and place of birth, image, nationality, passport and visa information, and travel history;

information regarding your reservation and guest stay information, including the hotels where you have stayed, dates of arrival and departure, goods and services ordered, special requests made, your service preferences (including room and vacation preferences);

your credit card details, and your account details and credentials for the Virgin Hotels guest rewards program;

information regarding the purchase and receipt of services;

information about vehicles you bring to our properties;

any information attendant to fulfilling special requests (e.g. health conditions that require specific accommodation or services, such as allergies);

information, feedback or content you provide regarding your marketing preferences, in surveys, sweepstakes, contests, or promotional offers, or on the Website or Platform;

your user preferences with respect to the Website and Platform.

reviews and opinions about our Hotels or services;

frequent flyer or travel partner program affiliation and member number;

recordings made by CCTV cameras in public places of our hotels; and

other types of information that you choose to provide to us or that we may obtain from third parties.

We collect this information when you visit our hotels, communicate the information to us, and use our Website or the Platform. We may also collect information from third parties such as airlines, payment card partners, and other partners.

If you want to sign up through our Website to receive our newsletter we will collect certain PII from you, including: your email address, name, date of birth, what you are interested in

hearing more about, and your guest preferences, including allergies.

Your Choice to Provide Information

You may choose what personal information (if any) you wish to provide to us. However, if you choose not to provide certain details, some of your experiences with us may be affected (for example, we cannot take a reservation without a name).
Centralized Information Storage and Processing.

Virgin Hotels uses certain centralized data processing systems, which may result in personal information being transferred between states or countries. The jurisdictions where the information will be transferred may or may not have laws that seek to preserve the privacy of personal information. However, whenever your personal information is transferred within Virgin Hotels, your personal information will be processed in accordance with the terms and conditions of this Policy.

How We May Use Your Personal Information

We may also use your information for the following purposes:

to help provide lodging and services to you and improve our offerings;

to send you our newsletter if you have signed up to receive it;

to carry out surveys occasionally and to analyze our user base — ultimately we want to ensure that the Website provides the types of content that you — our audience — is looking for;

to check whether you are eligible for a competition and to contact you if you win;

for marketing;

to administer our rewards program;

to comply with the law; or

otherwise as we feel is reasonably necessary to prevent illegal activity or to protect our interests.

How We May Share Your Information

Virgin Hotels may 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 and Website on our behalf. This third party technology provider may also own, manage and service the servers which power the Platform and Website and on which all user PII is stored, and may share all or some of such PII collected through the Platform and Website 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, or as otherwise required by law.

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 and/or Website. 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/or Website, 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 and/or Website. 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 and create anonymous and aggregate information based on the information provided to us. This information is not PII. On the website and platform, we may collect anonymous information about user preferences in navigating the Website and 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 usage, customize 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 automatically track certain anonymous information about Users based on usage. 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 and is anonymous with respect to individual Users. Virgin Hotels may create and maintain a file or activity for users about their current and past activities in using the Platform or Website, 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.

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 and/or Website. 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 functionality of the Platform and/or Website, including without limitation purchasing certain products and/or services through the Platform and Website.

Information that Is Not Secure

Any e-mail communication with Virgin Hotels is not secure. When requesting information or sending forms to us by e-mail, we recommend that you do not include any confidential information such as credit card information when using e-mail. For your protection, our e-mail responses to you will not include any confidential information. Be sure to always close your internet browsers when you are done using our Website of Platform.

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.
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, 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 and Website are 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 and/or Website. In such a case, a user must specify such a request in writing to Virgin Hotels, by email at info@virginhotels.com. Users may also contact Virgin Hotels if they have questions or concerns about any of our information collection or use practices at info@virginhotels.com.
Our Right of Assignment

Virgin Hotels’ rights under this Privacy Policy may be assigned by Virgin Hotels, in its sole discretion, to a third party or parties, and such an assignment will inure to the benefit of our successors, assigns and/or licensees.
How Is Personal Information affected by business transfers?

Virgin Hotels manages properties on behalf of third party owners. Guest information required for the business transaction between the Guest and the property may be shared with the property owner. If we cease to manage a particular property, certain guest information, including information required to process pending reservations and information, may be shared with the property owner, and will be retained by Virgin Hotels. Virgin Hotels requests that property owners abide by its privacy policy (as in effect from time to time), but Virgin Hotels cannot ensure that such owner(s) will in fact comply with the policy terms in all cases.

Links We Provide to Third Party Websites

The Platform and/or Website 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 the Personal Information we hold about you. You can write to us by email at info@virginhotels.com or at the following postal address requesting access to your PII: Virgin Hotels, LLC, Attention: Marketing Department, 3390 Mary Street | Suite 218 | Coconut Grove, FL 33133.

For Further Information

If you have any queries, comments or complaints regarding this Privacy Policy, please