PRIVACY STATEMENT

Last Updated: November 17, 2018

This privacy statement (“Statement”) applies to Villa Cathaya (collectively, „Villa Cathaya,” “we,” or “us”). At Villa Cathaya, we strive to deliver outstanding products, services, and experiences. We value your business and, more importantly, your loyalty. We recognize that privacy is an important issue. We have developed this Statement to explain our practices regarding the personal information we collect from you or about you on this site or via our apps, through written or verbal communications with us, when you visit our property, or from other sources. While this Statement broadly describes the practices we have adopted, local laws vary and some jurisdictions may place restrictions on our processing activities (e.g., certain jurisdictions may require affirmative consent to send marketing messages). Therefore, our actual practices in such jurisdictions may be more limited than those described herein in order to enable us to comply with local requirements. If you are a resident of the European Economic Area (EEA), please see Appendix A for additional information regarding Villa Cathaya’s use of your personal information.

By using any of our products or services and/or by agreeing to this Statement, e.g. in the context of registering for any of our products or services, you understand and acknowledge that we will collect and use personal information as described in this Statement.

Please note that this Statement does not apply to our processing of personal information on behalf of and subject to the instructions of third parties such as airlines, car rental companies and other service providers, companies that organize or offer packaged travel arrangements, marketing partners, or corporate customers.

PERSONAL INFORMATION WE COLLECT

We collect personal information at every touch point or guest interaction, and in conducting every aspect of our business, we may collect personal information. This personal information may include: your name, mailing address, billing address, email address, phone number, information related to your reservation, stay or visit to a property; participation in a contest, sweepstakes, or marketing program (even if you do not stay at one of our hotels); information related to the purchase and receipt of products or services; personal characteristics, nationality, income, passport number and date and place of issue; travel history; payment information, such as your payment card number and other card information, as well as authentication information and other billing and account details associated with mobile billing; guest preferences; marketing and communication preferences; information about vehicles you may bring onto our properties; reviews and opinions about our Portfolio of Brands or properties (if they are identified or associated with you); frequent flyer or travel partner program affiliation and member number; hotel, airline and rental car packages booked; groups with which you are associated for stays at hotels; and other types of information that you choose to provide to us or that we may obtain about you.

We may ask for details on joint travellers, including their names and frequent flyer numbers, and the age of the driver of the rental car. We may also collect information related to conversations, including recording or monitoring customer service calls for quality assurance and training purposes, and other communications such as in-app messages and SMS.

  • Surveys: We may request demographic data or other personal information in customer surveys.
  • On-property Collection:  We collect additional personal information during registration/check-in at our properties, including such information as may be required by local laws. We may also use closed circuit television and other security measures at our properties that may capture or record images of guests and visitors in public areas. We may also use closed-circuit television and other technologies that record sound or video for the protection of our staff, guests and visitors to our properties where permitted by law.
  • Social Media: If you choose to participate in Villa Cathaya – sponsored social media activities or offerings, we may collect certain information from your social media account consistent with your settings within the social media service, such as location, check-ins, activities, interests, photos, status updates and friend list. We may also allow you to enter into contests to provide photos, such as of your stay with us, which you may share with your connections on social media for votes, shared

In addition to the information we collect from you directly, we may also infer information about you based on the information you provide to us or from Other Information we collect.

PERSONAL INFORMATION WE COLLECT FROM THIRD PARTIES

We may also collect information about you from third parties, including information from our airline, payment card, and other partner; from your social media services consistent with your settings on such services; and from other third-party sources that are lawfully entitled to share your data with us. We use and share this information (and may append this information to the other information we have on file for you) for the purposes described in this Statement.

USE OF PERSONAL INFORMATION COLLECTED ABOUT YOU

We use your personal information in a number of ways, including to provide and personalize the services you request and expect from Villa Cathaya, to offer you the expected level of hospitality in-room and throughout our properties, conduct direct marketing and sales promotions and as set forth below in more detail. We will collect your consent prior to processing your data where required by applicable law.

We are obligated to collect certain data, including your name, address, payment information, and, in certain countries, travel document information, in order to process your reservation. Failure to provide this information will result in our inability to process your reservation.

  • Marketing and Communications: Where permitted we may use your personal information to provide or offer you newsletters, promotions and featured specials, as well as other marketing messages in accordance with any communications preferences you have expressed. We use your information to provide in-stay messaging and reservation confirmations; to send you marketing messages; and to conduct surveys, sweepstakes, prize draws, and other contests. We may provide these communications via email, postal mail, online advertising, social media, telephone, text message (including SMS and MMS), push notifications, in-app messaging, and other means (including on-property messaging, such as your in-room television). With your consent, we also use user-generated content (such as photos) from social media services to deliver display advertising or on our website and apps. We may also collect information from your payment card, which can be appended to personal information and used by Villa Cathaya or its business partners to recognize what type of card you have, such as the bank or network of the card, and present and/or send you targeted marketing messages based on your payment method and in accordance with your communication preferences. We may also partner with third parties to learn whether a visitor to our site has a cash-back offer associated with their payment card and to deliver the visitor advertising and information that explains how to take advantage of that offer through a stay at Villa Cathaya.
  • Service Improvements: We may use your personal information to improve our services and to ensure that our site, products, and services are of interest to you. We also use your personal information to provide you with the expected level of hospitality in-room and throughout our properties. This may include providing you with the ability to control your in-room technology through our website or apps on your personal devices.
  • Electronic Billing Program: We may enroll you in our automated billing program and use your email address to send you your hotel bill via email. It is your responsibility to ensure that we have the correct (and preferred) email address for you. If you make a reservation for another person using your email address, that person’s bill will be sent to your email address.
  • Data Correctness, Analytics and Personalization: We may aggregate your personal information with data from third-party sources for purposes of keeping information up to date and analytics. We also rely on information from third parties in order to provide better, more personalized service. For example, if you connect your social media services or other accounts to our services, we may use this information to make your experiences with us more personal and social, or share and use it as described elsewhere in this Statement.

PERSONAL INFORMATION WE SHARE

In order to offer you the expected level of hospitality and to provide you with the best level of service, we may share your personal information among our service providers, and other third parties as set forth in detail below:

  • Electronic Billing Program:  If you receive an bill by email (as discussed above), a summary detailing the goods and services provided to you during your stay will be shared with the payment card provider and, if you participate in a corporate billing program and use a corporate payment card, the payment card provider may share that summary with your employer. The privacy policies of your employer, the relevant payment card provider and card issuer apply once we have transferred your information.
  • Business Partners:  We may partner with other companies to provide you with products, services, or offers based upon your experiences at our properties and may share your information with our business partners accordingly. For example, we may help to arrange rental cars or other services from our business partners, and share personal information with our business partners in order to provide those services. We may also share your personal information, such as your email address, with our corporate travel partners to help them assess compliance with travel policies or participation in special rate plans or to engage in co-branded marketing with our corporate travel partners. We may also work with third parties, such as our airline and payment card partners, to allow us and our partners to deliver advertisements to our shared customers. Our partners may be able to provide more relevant offers to you based upon information that we share about your experiences at our properties. Additionally, we may allow third-party partners to recognize you when you visit that partner’s website or app, or to recognize you as one of their customers when you visit our websites or apps so that they may provide more relevant offers to you. We may share a hashed version of your email address with third parties using available security measures that may match it with their own hashed versions of email addresses so that they can send online and email advertisements to you on our behalf.
  • Co-Sponsors of Promotions:  We co-sponsor promotions, sweepstakes, prize draws, competitions or contests with other companies, and we provide prizes for sweepstakes and contests sponsored by other companies. If you enter one of these sweepstakes or contests, we may share your information with the co-sponsor or third-party sponsor.
  • On-property Services: We may share personal information with third-party providers of on-property services such as concierge services, spa treatments, golf, or dining experiences.
  • Service Providers:  We rely on third parties to provide services and products on our behalf and may share your personal information with them as appropriate. Generally, our service providers are contractually obligated to protect your personal information and may not otherwise use or share your personal information, except as may be required by law. However, our fraud detection service providers may use, but not share, your personal information for fraud detection purposes. We may use service providers to communicate news and deliver promotional and transactional materials to you on our behalf, including personalized online and mobile advertising in accordance with your preferences and applicable law. Please see our Cookies Statement for more information. Villa Cathaya will only work with parties that offer a method to opt-out of such advertising. We may also share information with service providers to allow you to create itineraries by selecting sites, activities, and restaurants from lists that we have personalized for you based on your preferences and third-party data.
  • Business Transactions:  As we develop our business, we might sell, buy, restructure or reorganize businesses or assets, or cease being the manager or franchisor of a villa that is currently part of our portfolio. In such circumstances, Villa Cathaya may transfer, sell or assign information collected, including, without limitation, Other Information (described below) and personal information, to one or more affiliated or unaffiliated third parties in connection with these business transactions. To the extent that local laws require it, we will provide notice of our intent to transfer personal data to a third party for this purpose, and explain how you can object to such transfer.
  • Telemarketing:  If you stay at our villa, we may share your telephone number among Limasan Padi, for purposes of telemarketing in accordance with your preferences and applicable law. We may also receive your telephone number from our partners or from other sources, which we may use for telemarketing purposes.
  • Other:  In addition, Villa Cathaya may disclose personal information in order to: (i) comply with applicable laws, (ii) respond to governmental inquiries or requests from public authorities, (iii) comply with valid legal process, (iv) protect the rights, privacy, safety or property of Hilton, site visitors, guests, employees or the public, (v) permit us to pursue available remedies or limit the damages that we may sustain, (vi) enforce our websites’ terms and conditions, and (vii) respond to an emergency.

OTHER INFORMATION

When you visit and interact with Villa Cathaya’s website and apps, we collect other information that does not directly identify you about your use of the site, such as a catalog of the site pages you visit, and the number of visits to our sites (“Other Information”). We use Other Information, as well as data received from third parties, to deliver you email, online (on our sites and other sites) and mobile advertisements. 

We use cookies and other technologies (such as “pixel tags,” “web beacons,” “clear GIFs”, links in emails, JavaScript, device IDs assigned by Google or Apple, or similar technologies) to collect this information. If you want to remove or block Cookies from your device at any time, you can update your browser settings (consult your browser’s “help” menu to learn how to remove or block Cookies). Villa Cathaya is not responsible for your browser settings. You can find good and simple instructions on how to manage Cookies on the different types of web browsers at www.allaboutcookies.org. Note for EEA and UK-Residents: If you are based in Europe, you also can adjust your Cookie preferences by adjusting the Cookie Settings through the Cookie Consent Manager, which can be found here: Cookie Preferences.

You can learn more about interest-based advertising and how to opt out of our vendors’ and other advertisers’ use of Cookies to tailor content or advertising to you by visiting http://optout.networkadvertising.org/#!/ and http://www.aboutads.info/choices.

At this time, we do not respond to Do Not Track signals or other, similar mechanisms.  Please see our Cookies Statement for more information.

We may use information we have collected and aggregated, or anonymized personal information received from third parties, to understand more about our users (for example, we may use aggregated information to calculate the percentage of our users who have a particular telephone area code). This includes demographic data, such as date of birth, gender and marital status, inferred commercial interests, such as favorite products or hobbies, and other information we may collect from you or from third parties.

Because Other Information does not personally identify you, such information may be disclosed for any purpose where permitted by law.  In some instances, we may combine Other Information with personal information. If we do combine any Other Information with personal information, the combined information will be treated by us as personal information in accordance with this Statement. 

SENSITIVE INFORMATION

The term “sensitive information” refers to information related to your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life, or sexual orientation, genetic information, criminal background, and any biometric data used for the purpose of unique identification. In some jurisdictions, mobile phone numbers, location data, and information contained on identity documents also are considered sensitive information.

We do not generally collect sensitive information unless it is volunteered by you or unless we are required to do so pursuant to applicable laws or regulations. We may use health data provided by you to serve you better and meet your particular needs (for example, the provision of disability access).

PERSONAL INFORMATION FROM CHILDREN

We do not knowingly collect personal information from individuals under 18 years of age. As a parent or legal guardian, please do not to allow your children to submit personal information without your permission.

LINKS TO THIRD-PARTY WEBSITES AND SERVICES

Our site and our mobile applications may contain links to third parties’ websites. Please note that we are not responsible for the collection, use, maintenance, sharing, or disclosure of data and information by such third parties. If you provide information on and use third-party sites, the privacy policy and terms of service on those sites are applicable. We encourage you to read the privacy policies of websites that you visit before submitting personal information.

Villa Cathaya may also 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.

PROTECTING PERSONAL INFORMATION

In the event of a security incident, Villa Cathaya will notify regulators and/or consumers as required by applicable laws or regulations.

We also seek to require our affiliates and service providers with whom we share personal information to exercise reasonable efforts to maintain the confidentiality of personal information about you. For online transactions, we use reasonable technological measures to protect the personal information that you transmit to us via our site. Unfortunately, however, no security system or system of transmitting data over the Internet can be guaranteed to be entirely secure.

For your own privacy protection, please do not send payment card numbers or any other confidential personal information to us via email.

We will not contact you by mobile/text messaging or email to ask for your confidential personal information or payment card details. We will only ask for payment card details by telephone when you are booking a reservation or promotional package. If you receive this type of request, you should not respond to it. We also ask that you please notify us at Villa.Cathaya@gmail.com.

RETAINING PERSONAL INFORMATION

We retain personal information about you for the period necessary to fulfill the purposes outlined in this Statement, unless a longer retention period is required or permitted by applicable law. We retain personal information collected in order to fulfill guest reservations for seven years after the stay is completed. We retain other personal information for shorter periods of time if possible and if permitted by law.

We will destroy your personal information as early as practicable and in a way that the information may not be restored or reconstructed.

If printed on paper, the personal information will be destroyed in a secure manner, such as by cross-shredding or incinerating the paper documents or otherwise and, if saved in electronic form, the personal information will be destroyed by technical means to ensure the information may not be restored or reconstructed at a later time.

CHOICES – MARKETING COMMUNICATIONS

If you have given us your contact information (mail address, fax number, email address or phone number), we may want to inform you in accordance with any preferences you have expressed, and with your consent where required, about our products and services or invite you to events via email, online advertising, social media, WeChat, WhatsApp, telephone, text message (including SMS and MMS), push notifications, postal mail and other means (including on-property messaging, such as your in-room television).

To opt out of text messages, tell the hotel front desk that you do not want to receive text messages from the hotel or reply “STOP” to the message you received.

STATEMENT MODIFICATIONS

We may modify this Statement from time to time. When we make material changes to this Statement we will post a link to the revised Statement on the homepage of our site, and if you have registered for any of your products or services, will may also inform you though a communications channel that you have provided. You can tell when this Statement was last updated by looking at the link and at the date at the top of the Statement. Any changes to our Statement will become effective upon posting of the revised Statement on the site. Use of the site, any of our products and services, and/or providing consent to the updated Statement following such changes constitutes your acceptance of the revised Statement then in effect.

CONTACT US

If you have any questions about this Statement or how Villa Cathaya processes your personal information, or if you wish to either provide a compliment or a complaint, please contact us by email at Villa.Cathaya@gmail.com. We will respond within 30 days or sooner if practicable.