Privacy Policy

Kimpton Hotel & Restaurant Group uses your personal information in order to fulfill our commitment to providing an unparalleled guest service experience. As part of that undertaking, we are committed to safeguarding the privacy of the personal information that we gather

As one of our guests, you understand and agree that we collect, use and disclose your personal information in accordance with this Privacy Policy for Guests (this "Policy").

TYPES OF PERSONAL INFORMATION WE COLLECT

The term "personal information" in this Policy refers to information which does or is capable of identifying you as an individual. The types of personal information that we process (which may vary by jurisdiction based on applicable law) include:

• Your name, gender, home and work contact details, business title, date and place of birth, nationality and passport and visa information;
• Guest stay information, including the hotels where you have stayed, date of arrival and departure, goods and services purchased, special requests made, observations about your service preferences (including room and holiday preferences), telephone numbers dialed and faxes and telephone messages received;
• Any information necessary to fulfill special requests (e.g., health conditions that require specific accommodation, purchase of goods and services);
• Information you provide regarding your marketing preferences or in the course of participating in surveys, contests or promotional offers;
• Information collected through the use of closed circuit television systems, card key and other security systems; and
• Contact and other relevant details concerning the employees of corporate accounts and vendors and other individuals with whom we do business (e.g., travel agents or meeting and event planners);
• Geolocation information for our mobile internet and iPhone app users, upon your consent.

Most of the personal information we process is information that you or someone acting on your behalf knowingly provides to us. However, in some instances, we process personal information that we are able to infer about you based on other information you provide to us or on our interactions with you, or personal information about you that we receive from a third party.

HOW WE USE INFORMATION

First, we analyze visitor information in aggregate, which means that we collect information about thousands of site visits and analyze it as a whole. This kind of study involves looking for trends among many visitors to our site, rather than analyzing information about any individual visitor. Examples include researching which parts of the site are accessed most frequently or determining which products are most attractive to our users.

Second, we may use specific information you provide to help us customize our communications with you and improve our service to you when you visit any Kimpton property, to conduct market research, customer satisfaction and quality assurance surveys and to direct marketing and sales promotions. For instance, if you inform us of a room or service preference, we will attempt to satisfy that request when you visit us in the future and may send you promotions relating to that preference.

We use third parties to build and manage these communication and preference systems, and our arrangements with these third parties prohibit them from disclosing your personal information.

Specifically, subject to applicable laws, we may collect, use and disclose relevant portions of your personal information in order to:

• Provide and charge for the hotel accommodation and other goods and services you purchase;
• Provide you with a better, more personalized level of service;
• Administer the Kimpton inTouch frequent guest program;
• Fulfill contractual obligations to you, anyone involved in the process of making your travel arrangements (e.g., travel agents, group travel organizers or your employer) and vendors (e.g., credit card companies, airline operators and other loyalty programs);
• Conduct market research,customer satisfaction and quality assurance surveys, direct marketing and sales promotions;
• Respond to requests for information and services;
• Provide for the safety and security of staff, guests and other visitors;
• Administer general record keeping; and
• Meet legal and regulatory requirements

SHARING OF PERSONAL INFORMATION

We reveal Personally Identifiable Information about you to unaffiliated third parties if:

• You request or authorize it;
• The information is provided to help complete a transaction for you;
• The information is provided to comply with the law, applicable regulations, court orders or subpoenas, to enforce our Terms of Use or other agreements, or to protect our rights, property or safety or the rights, property or safety of our users or others (e.g., to a consumer reporting agency for fraud protection etc.);
• The disclosure is done as part of a purchase, transfer or sale of services or assets (e.g., in the event that substantially all of our assets are acquired by another party, customer information may be one of the transferred assets);
• The information is provided to our agents, outside vendors or service providers to perform functions on our behalf (e.g., analyzing data, providing marketing assistance, providing customer service, processing orders, etc.); or
• To others as described in this Privacy Policy.