Privacy Statement
Live and Work Limited Privacy Statement
Last Updated May 23, 2018
Live and Work Limited, which includes The Town House, 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 Town House for data that we collect:
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through websites operated by us from which you are accessing this Privacy Statement, including www.thetownhouse.im and other websites owned or controlled by Live and Work Limited (collectively, the “Websites”)
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through the software applications made available by us for use on or through computers and mobile devices (the “Apps”)
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through our social media pages that we control from which you are accessing this Privacy Statement (collectively, our “Social Media Pages”)
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through HTML-formatted email messages that we send you that link to this Privacy Statement and through your communications with us
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when you visit or stay as a guest at one of our properties, or through other offline interactions
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through our pre-arrival questionnaire system
Collectively, we refer to the Websites, the Apps and our Social Media Pages, as the “Online Services” and, together with offline channels, the “Services.” By using the Services, you agree to the terms and conditions of this Privacy Statement.
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COLLECTION OF PERSONAL DATA
“Personal Data” are data that identify you as an individual or relate to an identifiable individual. At touch points throughout your guest journey, we collect Personal Data in accordance with law, such as:
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Name
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Gender
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Postal address
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Telephone number
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Email address
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Credit and debit card number or other payment data
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Financial information in limited circumstances
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Language preference
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Membership or loyalty program data (including co-branded payment cards, travel partner program affiliations)
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Employer details
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Travel itinerary, tour group or activity data
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Prior guest stays or interactions, goods and services purchased, special service and amenity requests
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Geolocation information
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Data about family members and companions, such as names and ages of children
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Images and video and audio data via: (a) security cameras located in public areas, such as hallways and lobbies, in our properties;
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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 soand you permit us to use the data in accordance with this Privacy Statement.
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HOW WE COLLECT PERSONAL DATA
We collect Personal Data in a variety of ways:
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Online Services. We collect Personal Data when you make a reservation, purchase goods and services from our Websites or Apps, Online Travel Agencies (Such as Booking.com, Expedia, etc), 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.
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Property Visits and Offline Interactions. We collect Personal Data when you visit our properties or use on-property services. We also collect Personal Data when you attend promotional events that we host or in which we participate, or when you provide your Personal Data to facilitate an event.
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Customer Care Centres. We collect Personal Data when you make a reservation over the phone, communicate with us by email, fax or via online chat services or contact customer service. These communications may be recorded for purposes of quality assurance and training.
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Internet-Connected Devices. We collect Personal Data from internet-connected devices available in our properties. For example, a smart home assistant may be available for your use and to tailor your accommodations and experience.
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Physical & Mobile Location-Based Services. We collect Personal Data if you download one of our Apps or choose to participate in certain programs. For example, we may collect the precise physical location of your device by using satellite, cell phone tower, WiFi signals, or other technologies. We will collect this data if you opt in through the App or other program (either during your initial login or later) to receive the special offers and to enable location-driven capabilities on your mobile device. If you have opted-in, the App or other program will continue to collect location data when you are in or near a participating property until you log off or close application (i.e., the App or other program will collect this data if it is running in the background) or if you use your phone’s or other device’s setting to disable location capabilities for Live and Work App or other program.
USE OF PERSONAL DATA AND OTHER DATA
We use Personal Data to provide you with Services, to develop new offerings and to protect Live and Work and our guests as detailed below. In some instances, we will request that you provide Personal 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 for our legitimate business interests, including the following:
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Provide the Services you request. We use Personal Data to provide Services you request, including:
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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
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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
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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 the reception desk
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We will use Personal 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.
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Personalise the Services according to your Personal Preferences. We use Personal Data to personalise the Services and improve your experiences, including when you contact our reception, visit one of our properties or use the Online Services, to:
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Customise your experience according to your Personal Preferences
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Present offers tailored to your Personal Preferences
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We will use Personal Data to provide personalised Services according to your Personal Preferences either with your consent or because we have a legitimate interest to do so.
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Communicate with you about goods and services according to your Personal Preferences. We use Personal Data to:
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Send you marketing communications and promotional offers, as well as periodic customer satisfaction, market research or quality assurance surveys
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We will use Personal 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.
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Loyalty Programs. We use Personal Data to:
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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
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Send you offers, promotions and information about your account status and activities
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Assess your benefits
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We will use Personal 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.
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Business Purposes. We use Personal Data for data analysis, audits, security and fraud monitoring and prevention (including with the use of closed circuit television, and other security systems), 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.
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We use Personal 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.
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DISCLOSURE OF PERSONAL DATA AND OTHER DATA
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Our goal is to provide you with the highest level of hospitality and Services, and to do so, we share Personal Data with the following:
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Live and Work Limited. We disclose Personal Data and Other Data to other companies within the Live and Work Limited for the purposes described in this Privacy Statement, such as providing and personalizing the Services, communicating with you, facilitating the loyalty programs, and to accomplish our business purposes. Live and Work Limited is the party responsible for the management of the jointly-used Personal Data. We share your Personal Data used for making a reservation with the applicable property to fulfil and complete your reservation.
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Service Providers. We disclose Personal Data to third-party service providers for the purposes described in this Privacy Statement. Examples of service providers include companies that provide website hosting, data analysis, payment processing, order fulfilment, information technology and related infrastructure provision, customer service, email delivery, marketing, auditing and other services.
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Corporate Reorganisation. We may disclose or transfer your Personal Data to a third party in the event of any reorganisation, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Live and Work business, assets or stock (including any bankruptcy or similar proceedings).
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OTHER USES AND DISCLOSURES
We will use and disclose Personal Data as we believe to be necessary or appropriate: (a) to comply with applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including authorities outside your country of residence and to meet national security or law enforcement requirements; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect the rights, privacy, safety or property of Live and Work Limited, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
SECURITY
We seek to use reasonable organisational, technical and administrative measures to protect Personal Data. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us.
LINKS TO OTHER WEB SITES
In order to anticipate your needs, our website provides links to other web sites and third parties for your convenience and information. We are not responsible for the collection, use, maintenance, sharing or disclosure of data (including personal data) by such third parties. We encourage you to contact these third parties to ask questions about their privacy practices, policies and security measures before disclosing any personal data. We recommend that you review the privacy statements and policies of linked web sites to understand how those web sites collect, use and store information.
CHOICES, ACCESS AND RETENTION
You have choices when it comes to how we use your data and we want to ensure you have the information to make the choices that are right for you.
If you no longer want to receive marketing-related emails, you may opt out by clicking our unsubscribe button at the bottom of any such email you receive from us. In addition, members of our loyalty programs can opt out from marketing-related emails through their program account, or by sending a letter to: The Town House, 24 Loch Promenade, Douglas, Isle of Man, IM1 2LX. We will try to comply with your request as soon as reasonably practicable. If you opt out of receiving marketing emails from us, we may still send you important administrative messages, from which you cannot opt out.
HOW YOU CAN ACCESS, CHANGE OR SUPPRESS YOUR PERSONAL DATA
If you would like to review, correct, update, suppress, restrict or delete Personal Data that you have previously provided to us, or if you would like to receive an electronic copy of your Personal Data for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by law), you can contact us at reception@thetownhouse.im, or by post:
The Town House
24 Loch Promenade
Douglas
Isle of Man
IM1 2LX
In your request, please make clear what Personal Data you would like to have changed, whether you would like to have your Personal Data suppressed from our database, or other limitations you would like to put on our use of your Personal Data. For your protection, we only fulfil requests for the Personal Data associated with the particular email address that you use to send us your request, and we may need to verify your identity before fulfilling your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we often need to retain certain data for record keeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or reservation, or enter a promotion, you may not be able to change or delete the Personal Data provided until after the completion of such purchase, reservation, or promotion). There may also be residual data that will remain within our databases and other records, which will not be removed. In addition, there may be certain data that we may not allow you to review for legal, security or other reasons.
RETENTION
We will retain your Personal Data for the period necessary to fulfil the purposes outlined in this Privacy Statement unless a longer retention period is required or permitted by law.
The criteria used to determine our retention periods include:
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The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services)
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Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them)
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Whether retention is advisable considering our legal position (such as, for statutes of limitations, litigation or regulatory investigations)
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SENSITIVE DATA
Unless specifically requested, we ask that you not send us, and you not disclose, on or through the Services or otherwise to us, any Sensitive Personal Data (e.g., social security numbers, national identification number, data related to racial or ethnic origin, political opinions, religion, ideological or other beliefs, health, biometrics or genetic characteristics, criminal background, trade union membership, or administrative or criminal proceedings and sanctions).
USE OF SERVICES BY MINORS
The Services are not directed to individuals under the age of sixteen (16), and we request that they not provide Personal Data through the Services.
UPDATES TO THIS PRIVACY STATEMENT
The “LAST UPDATED” legend at the top of this page indicates when this Privacy Statement was last revised. Any changes will become effective when we post the revised Privacy Statement on the Online Services. Your use of the Services following these changes means that you accept the revised Privacy Statement. If you would like to review the version of the Privacy Statement that was effective immediately prior to this revision, please contact us at reception@thetownouse.im.
CONTACTING US
If you have any questions about this Privacy Statement, please contact us at reception, or by post:
The Town House
24 Loch Promenade
Douglas
Isle of Man
IM1 2LX
Because your email communications to us may not always be secure, please do not include credit card or Sensitive Data in your emails to us.