Dear user of Wanda Hotels & Resorts,
Wanda Hotels & Resorts pledges to deliver the high level of customer service, which includes respecting your privacy and protecting your personal information. The privacy and security of your information is very important to us. Whether you are visiting our website, booking a room, or are a member of our loyalty program, we want you to trust the way that we manage your information and to keep you informed about how we use that information.
According to Personal Information Protection Law of the People's Republic of China, in this privacy statement ("Statement"), we provide you with details about how we collect, use, protect and disclose your personal information.
This Statement applies to?Wanda Hotels & Resorts and all of hotels managed by Wanda Hotels & Resorts.
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.
We collect personal information directly from you, information about you from other persons/entities/online channels, and automatically when you use our website or other Wanda Hotels & Resorts digital channels, and through certain offerings or services available at Wanda Hotels & Resorts properties (such as WI-FI). We provide more details in the sections below. In particular, we collect and use information about you if you (or someone on your behalf) make a reservation to stay at a Wanda Hotel & Resorts property, participate in the loyalty program, or interact with us through other Wanda Hotels & Resorts digital channels. You do not have to provide us with your personal information in order to use our website; in some cases, however, we may not be able to provide services to you without your personal information (for example, we would not be able to complete a requested booking or enroll you in our rewards program). To learn more about how we collect, use and share your information and how you can opt out, please click on the relevant section below.
At touchpoints throughout your guest journey, we collect Personal Data in accordance with the law, and to serve you better.?Personal Data?is information that may identify you as an individual or relate to you as an identifiable individual. We collect and process the following types of Personal Data about you:
?Financial information (such as credit and debit card number or other payment data)
?Date of birth
?Nationality, passport, visa, or other government-issued identification data
?Important dates: birthdays, anniversaries, and special occasions
?Membership or loyalty program data (including travel partner program affiliations)
?Employer details (for business-related bookings)
?Travel itinerary, tour group, or activity data
?Prior guest stays or interactions, goods and services purchased, special service and amenity requests
In more limited circumstances, we may also collect:
?Data about family members and companions, names and ages of children
?Images, video and audio data via: security cameras located in public areas, such as hallways and lobbies.
In order to meet your requirements or provide you with a specific service (such as dietary requirements), we may have to collect sensitive information, such as information concerning race, ethnicity, political opinions, religious and philosophical beliefs, union membership, or details of health or sexual orientation. In this case, we will only process this data if you provide your express prior consent.
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.
Personal data may be collected on a variety of occasions, including:
1. Hotel activities:
?Booking a room
?Checking-in and paying
?Hotel stays and services provided during a stay
?Eating/drinking at the hotel bar or restaurant during a stay
?Requests, complaints and/or disputes.
2. Participation in marketing programs or events:
?Signing up for the loyalty program
?Participation in customer surveys (for example, the Guest Satisfaction Survey)
?Subscription to newsletters, in order to receive offers and promotions via email.
3. Transmission of information from third parties:
?Tour operators, travel agencies (online or not), GDS reservation systems and others
4. Internet activities:
?Connection to Wanda Hotels & Resorts websites (IP address, cookies in accordance with our?Policy about the use of tracers)
?Online forms (online reservation, questionnaires,).
2.The legal basis for processing your personal data
We are committed to collecting and using your information in accordance with applicable data protection laws.
We collect, use and share your information where we have an appropriate legal basis to do this.
This may be because:
?You have provided your consent to us using the personal information;
?Our use of your information is necessary to perform our contract with you, for example, making and managing your booking and operating and providing services in connection with our Loyalty Program in accordance with the terms of our agreement with you;
?Our use of your information is necessary to meet responsibilities we have to our regulators, tax officials, law enforcement, or otherwise meet our legal responsibilities;
?Our use of your information is in our legitimate interest as a commercial organization, for example, to operate and improve our services and to keep people informed about our products and services (including for profiling and targeted advertising) – in these cases we will look after your information at all times in a way that is proportionate and respects your privacy rights and you have a right to object to processing of your information.
If you would like to find out more about the legal basis for which we process personal information please contact us (details found in the?How to contact us?section). If you have provided your consent to our processing of your information you can withdraw this consent at any time by contacting Wanda Hotels & Resorts (details found in the?How to contact us?section).
Wanda Hotels & Resorts is committed to protecting the confidentiality and security of the information that you provide to us. To do this, technical, physical and organizational security measures are put in place to protect against any unauthorized access, disclosure, damage or loss of your information. The collection, transmission and storage of information can never be guaranteed to be completely secure, however, we take steps to ensure that appropriate security safeguards are in place to protect your information. To this end, we have taken technical measures (such as firewalls) and organizational measures (such as a user ID/password system, means of physical protection etc.) to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services.
Wanda Hotels& Resorts employs a robust team of dedicated information security professionals who are responsible for managing Wanda Hotels & Resorts security program. This team is responsible for, among many other things, monitoring our systems for potential intrusions, responding to potential incidents, supporting property-level information security, regularly reviewing and updating the security controls Wanda Hotels & Resorts uses to protect data, and providing training on Wanda Hotels & Resorts’ information security program.
We require third parties with whom we share personal information to exercise reasonable efforts to maintain the confidentiality of personal information.
We will never ask you to send us confidential personal information or payment card information via email or text message.
In the event of a security incident, Wanda Hotels & Resorts will notify regulators and/or consumers as required by applicable laws and regulations.
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 in accordance with the “Contact Us” section, below.
4.International Data Transfers
As we operate via a global network of corporate offices, reservations and service centers, data centers and hotels, it may be necessary to transfer your information, for example, information collected in connection with making a reservation or your stay at a Wanda hotel, joining in our loyalty program Wanda Club or interacting with us through our websites, emails or our other digital channels to China, where Wanda Hotels & Resorts Headquarters is located. The information that you provide us during the course of a reservation or through the provision of any other services may be transferred to any of our Wanda Hotels & Resorts affiliated entities and Wanda hotels around China for the purposes of carrying out or facilitating these services. It will also be necessary to transfer this information to other entities, including, without limitation, our Wanda Hotels & Resorts hotels, partners and our service providers in China.
Where we transfer information that originates in the country outside of China to mainland China, we will take steps to make sure such transfer is carefully managed to protect your privacy rights:
?Transfers within the Wanda Group will be covered by an agreement entered into by members of the Wanda Group (an intra-group agreement) which contractually obliges each member to ensure that your information receives an adequate and consistent level of protection wherever it is transferred within the Wanda Hotels & Resorts;
?where we transfer your data outside of the Wanda Hotels & Resorts including to other companies providing us with a service, we will obtain contractual commitments and assurances from them to protect your information. Some of these assurances are well-recognized certification schemes such as standard contractual clauses;
?We will only transfer personal information to China or countries which are recognized as providing an adequate level of legal protection or where we can be satisfied those alternative arrangements are in place to protect your privacy rights; and
?Any requests for information we receive from law enforcement or regulators will be carefully validated before personal information is disclosed.
When we otherwise transfer personal information between jurisdictions, we will take such steps as required by local law in an effort to ensure that such transfer is managed to protect your privacy rights.
5.Disclosure pursuant to legal obligations or to protect the safety and security of people and property.
Wanda Hotels & Resorts will disclose personal information as required by law. Examples of such disclosures include when countries require Wanda Hotels & Resorts to collect personal data about visitors to properties in that country, when a law enforcement agency serves a valid subpoena on Wanda Hotels & Resorts, and when a civil litigation serves a lawful discovery request on Wanda Hotels & Resorts. Wanda Hotels & Resorts may elect to share personal information with law enforcement or others as necessary to protect the safety and security of people and property, to pursue available remedies or limit the damages that we may sustain, and to respond to an emergency.
6.Cookie and Other Data
Cookie What is a cookie:?A “cookie” is a small text file that is placed onto an internet user’s web browser or device and is used to remember as well as obtain information about that part. You might be assigned a cookie when visiting our websites or other digital channels. In some instances, where permitted under the applicable law, cookies may also be used for the purposes of certain email campaigns.
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 browser type, time spent on the online services, pages visited, referring URL, language preferences, and other aggregated traffic data.
Functional Cookies?– these cookies support the use of the website and enable certain features to enhance your experience. For example, we use functional cookies to facilitate your reservation and to remember your selections as you move from page to page. We also use functional cookies for remembering things like your sign-in information and hotel preferences to avoid you having to re-enter it.
Performance Cookies?– these cookies collect information needed to support the website and our applications and allow us to improve our website and identify any problems that you faced while visiting us. For example, performance cookies may provide us with information about how you came to our website and how you navigated around our website during your visit. We also use these cookies to provide us with certain statistical and analytics information, such as how many visitors came to our website or how effective our advertising is.
Targeting Cookies?– these cookies are used to collect information from you to help us to improve our products and services as well as serve you with targeted advertisements that we believe will be relevant for you. We use targeting cookies across our websites and applications for various marketing initiatives and campaigns.
Third Party Advertising:
We may use third-party advertising companies to serve advertisements regarding goods and services that may interest you when you access and use the online services or other websites. To serve such advertisements, these companies place or recognize a unique cookie on your browser (including through use of pixel tags).
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 Apple), 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 you are using. We use this data to ensure that the online services function properly.
Pixel Tags and other similar technologies:
We collect data from pixel tags (also known as web beacons and clear GIFs), which are used with some online services to, among other things, track the actions of users of the online services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Online Services.
Your IP Address:
We collect your IP address, a number that is automatically assigned to the device that you are using by your Internet Service Provider (ISP). An IP address is identified and logged automatically in our server log files when a user accesses the online services, along with the time of the visit and the pages that were visited. We use IP addresses to calculate usage levels, diagnose server problems and administer the online services. We also may derive your approximate location from your IP address.
7.Use of WI-FI Service
When you use the WI-FI service in Wanda Hotels & Resorts properties, we may collect and process certain additional information.
What information we collect
Registration and User-Provided Information:
When you register to use the WI-FI service in Wanda Hotels & Resorts properties, we may collect personal information about you including your last name, your Wanda Club member, your room number and, depending on your location and applicable law, other personal information (such as your mobile phone number).
In the course of providing WI-FI service, we may automatically collect a device identifier (such as your IP address, MAC address, device name or other unique identifier) for the computer, mobile device, technology or other device you use to access WI-FI in Wanda Hotels & Resorts properties. A device identifier is a number that is automatically assigned to your device when you access WI-FI in Wanda Hotels & Resorts properties, and we may identify your device by its device identifier. When you use WI-FI in Wanda Hotels & Resorts properties, we may view your device identifier and use this information to enhance our service. We may associate your device identifier with other information about you, such as your Wanda Club member number.
Other device information:?
We may also automatically record certain information from your device including, device type, the web pages, apps or sites that you visit, and the dates and times that you visit, access, or use WI-FI (Internet activity information). While this information is generally pseudonymous and/or aggregated, this information may be associated with your Wanda Club member number and/or persistent identifiers. This data helps us to manage our networks and provides us with information about the use of WI-FI. We do not, however, collect and process the contents of email communications or other electronic communications you send or receive when using WI-FI.
We may collect information about your location through your use of the WI-FI services we provide at our hotels to enable us to improve our service and provide certain services to you such as customized offers and promotions.
8.Data retention periods
9.Link to other Sites
Our websites and applications contain links to websites that are maintained and/or controlled by non-affiliated parties. In some instances, these websites may be co-branded and display our logos or other trademarks. You can always tell whether you are on one of our websites by checking the uniform record locator ("URL”) on the page that you are visiting. We encourage you to review the privacy policies of these websites as their privacy practices may differ from ours.
10.Use of Service by Children and Minors
Our websites are not intended for children and we do not intentionally solicit or collect personal information from individuals under the age of 18. If we are notified or otherwise discover that a minor’s personal information has been improperly collected, we will take all commercially reasonable steps to delete that information. In limited instances, we may have a campaign or program targeted toward children. In these instances, details on the information practices will be presented within the terms and conditions of the program or campaign.
11.Changes to this Privacy Statement
In some instances, we may have to change, modify or amend this Privacy Statement in order to comply with the evolving regulatory environment or the needs of our business. Subject to any applicable legal requirements to provide additional notice, any changes to this Privacy Statement will be communicated through our websites. However, if there will be changes made to the use of your personal information in a manner different from that stated at the time of collection, we will take appropriate steps to notify you, such as by posting a notice on our website for 15 working days prior to the changes taking effect or by emailing you. We will obtain your consent to such changes where required to do so by applicable law.
For any questions, concerns or suggestions regarding to this Privacy Statement, please send email to Callcenter@wandahotels.com .
Normally, your email shall be replied within fifteen days. For any unsatisfaction or concern regarding to the reply, or in particular, the personal information processing has harmed your legal rights, you shall also seek the solution from the external channels:
a.To file a civil lawsuit with the people's court where the defendant is located;
b.To report to Cyberspace Administration of China (the website is: https://www.12377.cn/ , telephone number is: 12377).
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