Privacy

PRIVACY POLICY FOR CONDADO OCEAN CLUB ONLINE

‍Last Updated: October 22, 2020
Condado Ocean Club values you as our guest and recognizes that privacy is important to you. We want you to be familiar with how we collect, use and disclose data.

This Privacy Statement describes the privacy practices of the Condado Ocean Club for data that we collect

• through website(s) operated by us from which you are accessing this Privacy Statement: condadooceanclub.com
  
• through our social media pages that we control from which you are accessing this Privacy Statement (collectively, our “Social Media Pages”)
  
• through HTML-formatted email messages that we send you that link to this Privacy Statement and through your communications with us
  
• Collectively, we refer to the Websites, the Apps and our Social Media Pages, as the “Online Services”. By using the Services, you agree to the terms and conditions of this Privacy Statement.  Please note, this Privacy Policy does not apply to information collected outside of the Online Services.
  

Collection of Personal Data
“Personal Data” is data that identifies you as an individual.
At touchpoints throughout your digital guest journey, we collect Personal Data in accordance with law, such as:

• Name
• Gender
• Postal address
  
• Telephone number
  
• Email address
  
• Credit and debit card number or other payment data
  
• Financial information in limited circumstances
  
• Language preference
  
• Date and place of birth
  
• Nationality, passport, visa or other government-issued identification data
  
• Important dates, such as birthdays, anniversaries and special occasions
  
• Membership or loyalty program data (including co-branded payment cards, travel partner program affiliations)
  
• Employer details
  
• Travel itinerary, tour group or activity data
  
• Prior guest stays or interactions, goods and services purchased, special service and amenity requests
  
• Geolocation information
  
• Social media account ID, profile photo and other data publicly available, or data made available by linking your social media and loyalty accounts
  

In more limited circumstances, we also may collect:

• Guest preferences and personalized data (“Personal Preferences”), such as your interests, activities, hobbies, food and beverage choices, services and amenities of which you advise us or which we learn about during your visit
  

If you submit any Personal Data about other people to us or our Service Providers (e.g., if you make a reservation for another individual), you represent that you have the authority to do so and you permit us to use the data in accordance with this Privacy Statement.

How we Collect Personal Data
We collect Personal Data in a variety of ways:

• Online Services. We collect Personal Data when you make a reservation, purchase goods and services from our Website(s), communicate with us, or otherwise connect with us or post to social media pages, or sign up for a newsletter or participate in a survey, contest or promotional offer.
  
• Other Sources. We collect Personal Data from other sources, such as public databases, joint marketing partners and other third parties.
  
• Strategic Business Partners. We collect Personal Data from companies with whom we partner to provide you with goods, services or offers based upon your experiences at our properties or that we believe will be of interest to you (“Strategic Business Partners”). Examples of Strategic Business Partners include on-property outlets, travel and tour partners, time share partners, rental car providers and travel booking platforms. Strategic Business Partners are independent from the Condado Ocean Club.
  

COLLECTION OF OTHER DATA
“Other Data” are data that generally do not reveal your specific identity or do not directly relate to an individual. To the extent Other Data reveal your specific identity or relate to an individual, we will treat Other Data as Personal Data. Other Data include:

• Browser and device data
  
• Data collected through cookies, pixel tags and other technologies
  
• Demographic data and other data provided by you
  
• Aggregated data
  

Personal information once “de-identified” is not subject to this Privacy Policy and we may treat it as non-personal information and use it without obligation to you except as prohibited by applicable law.

HOW WE COLLECT OTHER DATA
‍We collect Other Data in a variety of ways:

• Your browser or device. We collect certain data through your browser or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, internet browser type and version and the name and version of the Online Services (such as Google Analytics, MailChimp, Facebook, etc.) you are using. We use this data to ensure that the Online Services function properly.
  
• Cookies.
  

We collect certain data from cookies, which are pieces of data stored directly on the computer or mobile device that you are using. Cookies allow us to collect data such as browser type, time spent on the Online Services, pages visited, referring URL, language preferences, and other aggregated traffic data. We use the data for security purposes, to facilitate navigation, to display data more effectively, to collect statistical data, to personalize your experience while using the Online Services and to recognize your computer to assist your use of the Online Services. We also gather statistical data about use of the Online Services to continually improve design and functionality, understand how they are used and assist us with resolving questions.

Cookies further allow us to select which advertisements or offers are most likely to appeal to you and display them while you are using the Online Services or to send marketing emails. We also use cookies to track responses to online advertisements and marketing emails.

You can see more detail on our Cookies, how they work, and what we use them for in the COOKIES section of this Privacy Statement.

• Aggregated Data. We may aggregate data that we collected and this aggregated data will not personally identify you or any other user.
  

USE OF PERSONAL DATA AND OTHER DATA
‍We use Personal Data and Other Data to provide you with Services, to develop new offerings and to protect the Condado Ocean Club and our guests as detailed below. In some instances, we will request that you provide Personal Data or Other Data to us directly. If you do not provide the data that we request, or prohibit us from collecting such data, we may not be able to provide the requested Services.

We use Personal Data and Other Data for our legitimate business interests, including the following:

• Provide the Services you request. We use Personal Data and Other Data to provide Services you request, including:
  

• To facilitate reservations, payment, send administrative information, confirmations or pre-arrival messages, to assist you with meetings and events and to provide you with other information about the area and the property at which you are scheduled to visit
  
• To complete your reservation and stay, for example, to process your payment, ensure that your room is available and provide you with related customer service
  
• To support our electronic receipt program. When you provide an email address in making a reservation, we use that email address to send you a copy of your bill. If you make a reservation for another person using your email address, that person’s bill will be emailed to you, as well. You can opt out of receiving your bill via email and instead receive a paper copy by contacting us at reservations@condadooc.com.
  

We will use Personal Data and Other Data to manage our contractual relationship with you, because we have a legitimate interest to do so and/or to comply with a legal obligation.

• Personalize the Services according to your Personal Preferences. We use Personal Data and Other Data to personalize the Services and improve your experiences, including when you contact our call center, visit one of our properties or use the Online Services, to:
  

• Customize your experience according to your Personal Preferences
  
• Present offers tailored to your Personal Preferences
  

We will use Personal Data and Other Data to provide personalized Services according to your Personal Preferences either with your consent or because we have a legitimate interest to do so.

• Communicate with you about goods and services according to your Personal Preferences. We use Personal Data and Other Data to:
  

• Send you marketing communications and promotional offers, as well as periodic customer satisfaction, market research or quality assurance surveys
  

We will use Personal Data and Other Data to communicate with you with your consent, to manage our contractual relationship with you and/or because we have a legitimate interest to do so.

• Loyalty Programs. We use Personal Data and Other Data to:
  

• Offer and manage your participation in our global loyalty programs, as well as others that are specific to certain properties or tailored to your interests
  
• Send you offers, promotions and information about your account status and activities
  
• Assess your benefits
  
• Manage your choices regarding how you wish to earn, track and use your points
  

We will use Personal Data and Other Data in this way with your consent, to manage our contractual relationship with you and/or because we have a legitimate interest to do so.

• Sweepstakes, activities, events and promotions. We use Personal Data and Other Data to allow you to participate in sweepstakes, contests and other promotions and to administer these activities. Some of these activities have additional rules and may contain additional information about how we use and disclose your Personal Data. We suggest that you read any such rules carefully.
  

We use Personal Data and Other Data in this way with your consent, to manage our contractual relationship with you and/or because we have a legitimate interest to do so.

• Business Purposes. We use Personal Data and Other Data for data analysis, audits, security and fraud monitoring and prevention, developing new goods and services, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
  

We use Personal Data and Other Data in this way to manage our contractual relationship with you, comply with a legal obligation and/or because we have a legitimate interest to do so.

‍Disclosing Personal Data and Other Data We Collect

‍We may share your information, including Personal Data and Other Data, with third parties for any purposes consistent with this Privacy Policy or as permitted by applicable law, including as follows:

• Service Providers and companies within the Condado Ocean Club.  We may disclose your information to third party service providers, including agents, contractors and other Condado Ocean Club companies, to use your Personal Data and Other Data on our behalf for the purposes set forth in this Privacy Policy.  Examples of such third parties include those who provide us with services such as website hosting, professional services, including information technology services and related infrastructure, customer service, marketing, e-mail delivery, auditing and other similar services.
  
• Business Partners and other Third Parties, for marketing purposes.  We may disclose your Personal Data and Other Data to third parties so they can provide marketing services or conduct marketing or social interaction activities on our behalf such as campaigns, contests, sweepstakes, loyalty programs, market research, customer surveys and data analytics to help us improve and tailor our marketing activities, products and services.
  
• Sharing at Your Request. We may disclose your Personal Data and Other Data to third parties in order to perform services you request or functions you initiate, such as when you post information and materials on our message boards and forums. When you post information in a public forum it becomes public information, and you are solely responsible for that information. In addition, we may disclose your information in order to identify you to anyone to whom you send communications through the Online Services.
  
• Corporate Reorganization. We may disclose or transfer your Personal Data and Other Data to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of the Condado Ocean Club business, assets or stock (including any bankruptcy or similar proceedings).
  

Other Legal Reasons. We may use or disclose Personal Data and Other Data as we deem necessary or appropriate: (1) under applicable law, including laws outside your country of residence; (2) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (3) to comply with subpoenas and other legal processes; (4) to allow us to pursue available remedies or limit the damages that we may sustain; (5) to protect our operations or those of any of our affiliates; (6) to protect the rights, privacy, safety or property of Condado Ocean Club, our affiliates, you and others; and (7) to enforce our terms and conditions.

Without limiting the foregoing, in our sole discretion, we may share aggregated data which does not identify you or de-identified information about you with third parties or affiliates for any purpose, except as prohibited by applicable law.

‍Transmission, storage and security of your Personal Data

‍No data transmission over the internet, a website, a mobile application, email or other message service can be guaranteed to be secure from intrusion. However, we implement and maintain commercially reasonable organizational, technical and administrative safeguards to protect your Personal Data in accordance with applicable law.

All Personal Data we collect about you is stored on our private dedicated server. We comply with our security policies and standards when accessing and using this information and restrict access to your Personal Data to those persons who need to use it for the purpose(s) for which it was collected.

Your Personal Data may be transferred outside the country in which you are located, including to countries with a lower level of data protection than in the country in which you are located.

We will retain your Personal Data for as long as is necessary for the processing purpose(s) for which it was collected, for as long as your account is active or as reasonably useful for commercial purposes. We will retain and use your Personal Data as necessary to comply with our legal obligations or data retention policies, resolve disputes, and enforce our agreements.

‍Your rights and contacting us

‍You have the right (subject to various exceptions and in accordance with data protection legislation in your country and/or jurisdiction) to access certain Personal Data about you and correct any inaccuracies. We may charge a reasonable fee for the processing of any data access request in accordance with applicable law in your country. You also have the right to raise a complaint about our processing with the data protection regulator in your jurisdiction.

You have the right to ask us not to process your Personal Data for direct marketing purposes. You can exercise your right to prevent such processing by indicating that you do not consent to direct marketing at the point at which we collect your Personal Data. You can also exercise the right at any time after we have collected and used your Personal Data for direct marketing purposes by:

• Following the opt-out instructions contained in the relevant communications; or
  
• Contacting us as detailed below.
  

If you are a data subject in the European Economic Area, you have the right to access, rectify, or erase any personal data we have collected about you through the Online Services. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you through the Online Services. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.  To exercise any of these rights, contact us as set forth below.

If you have any questions regarding our privacy practices, our data practices or our compliance with applicable law, you can contact us at: reservations@condadooceanclub.com.

‍Updates to this Policy

‍We may change this Privacy Policy from time to time. Any changes will be effective immediately upon posting of the revised Privacy Policy. If we make any material changes to this Privacy Policy, we will post those changes through a prominent notice on the website to notify you directly. Regardless of our efforts, we encourage you to review this Privacy Policy each time you visit the Online Services.

COOKIE POLICY FOR CONDADO OCEAN CLUB

What Are Cookies
‍As is common practice with almost all professional websites this site uses cookies, which are tiny files that are downloaded to your computer, to improve your experience. This page describes what information they gather, how we use it and why we sometimes need to store these cookies. We will also share how you can prevent these cookies from being stored however this may downgrade or ‘break’ certain elements of the sites functionality.

For more general information on cookies and how to disable cookies, visit http://www.allaboutcookies.org/.

‍How We Use Cookies
‍We use cookies for a variety of reasons detailed below. Unfortunately, in most cases there are no industry standard options for disabling cookies without completely disabling the functionality and features they add to this site. It is recommended that you leave on all cookies if you are not sure whether you need them or not in case they are used to provide a service that you use.

‍Disabling Cookies
‍You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionality and features of  this site. Therefore it is recommended that you do not disable cookies.

‍The Cookies We Set

• Email newsletters related cookies
  This site offers newsletter or email subscription services and cookies may be used to remember if you are already registered and whether to show certain notifications which might only be valid to subscribed/unsubscribed users.
  
• Orders processing related cookies
  This site offers e-commerce or payment facilities and some cookies are essential to ensure that your order is remembered between pages so that we can process it properly.
  
• Forms related cookies
  When you submit data through a form such as those found on contact pages or comment forms, cookies may be set to remember your user details for future correspondence.
  
• Email newsletters related cookies
  In some special cases we also use cookies provided by trusted third parties. The following section details which third party cookies you might encounter through this site.
  
  This site uses Google Analytics which is one of the most widespread and trusted analytics solution on the web for helping us to understand how you use the site and ways that we can improve your experience. These cookies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content.For more information on Google Analytics cookies, see the official Google Analytics page.
  
  Third party analytics are used to track and measure usage of this site so that we can continue to produce engaging content. These cookies may track things such as how long you spend on the site or pages you visit which helps us to understand how we can improve the site for you.
  
  From time to time, we test new features and make subtle changes to the way that the site is delivered. When we are still testing new features, these cookies may be used to ensure that you receive a consistent experience whilst on the site whilst ensuring we understand which optimizations our users appreciate the most.
  
  As we sell products it’s important for us to understand statistics about how many of the visitors to our site actually make a purchase and as such, this is the kind of data that these cookies will track. This is important to you as it means that we can accurately make business predictions that allow us to monitor our advertising and product costs to ensure the best possible price.
  
  We also use social media buttons and/or plugins on this site that allow you to connect with your social network in various ways. For these to work, social media sites, such as Facebook, Instagram, Linkedin, Pinterest and Twitter, will set cookies through our site which may be used to enhance your profile on their site or contribute to the data they hold for various purposes outlined in their respective privacy policies.
  
  We have no control over third party services or devices and are not responsible for the privacy policies and practices of third parties. Any information collected or stored by third parties are subject their own privacy policies and practices. You should consult the privacy policies of third parties.