Four Seasons Privacy Notice

Last Updated: July 1, 2020

Four Seasons Hotels and Resorts (“Four Seasons”, “we”, “us” and “our”) takes the issue of safeguarding your privacy seriously. Our Privacy Notice describes what information we collect from hotel guests, Residence Club and Private Residence owners, prospective Residence Club and Private Residence owners, renters and exchange guests (collectively referred to as "Guests and Owners") as well as visitors to the Four Seasons website and mobile App, and the way in which Four Seasons uses this information to better serve your needs.

This Privacy Notice has been adopted by all of the distinct legal entities that manage and operate Four Seasons branded hotels, resorts and residential properties. Those entities include Four Seasons Hotels Limited and its direct and indirect subsidiaries and affiliates, and all of the separate and distinct legal entities that manage Four Seasons managed hotels, resorts and residential properties worldwide. References to “we”, “us”, “our” and “Four Seasons” throughout this Privacy Notice, depending on the context, refer collectively to those separate and distinct legal entities.

What personal information do we collect?

Personal information is any information that may identify or relate to you as an identifiable individual. The personal information that we collect about you could include:

  • Identity information – such as name, age, gender, passport information or data from government-issued identity cards;
  • Contact information – such as your home address, zip/postal code, email address and phone number;
  • Images – such as CCTV images, publicly available photographs and images captured at events or during your stay
  • Financial and payment information – such as your credit card details, itemized spending and transaction history;
  • Reservation information – such as the type and location of the rooms you reserve and the dates of your reservations;
  • Health information – where disclosed and relevant to the provision of services;
  • Preference information – such as special requests, service issues and other preferences for your stay;
  • Public information – such as when we review public platforms to understand what you are saying about us or the hospitality industry;
  • Technical information – such as information about the device you use to interact with us (including the unique device identifier, hardware model, IP address, geolocation, operating system and version, and mobile network information and unique device identifiers, in the case of our mobile App); and
  • Correspondence information – when you contact us, such as to send an enquiry or make a request, any correspondence or application may be kept and added to your personal information.

How do we use your personal information?

For each of the categories of personal information described above, we use your personal information for the following purposes:

  • to enable you to use our website and our mobile App;
  • to help us recognize or identify you and any accounts you hold with us;
  • to provide superior customer service to you;
  • to assist us in making your reservation and providing the services you request at any of our properties;
  • to process transactions through our website (including taking payment for purchases you may make through our website) and to assist in any inquiries about your transaction;
  • for billing purposes in relation to your stay with us;
  • to confirm prior transactions and reconcile statements or invoices;
  • to contact you in relation to matters that arise from your stay with us;
  • to send you newsletters or marketing communications regarding our properties and to advise you of promotions or to inform you of offers or other information that may be of interest to you (if, where required, you separately provide your consent for us to do so);
  • to personalize and enhance your online and guest experience;
  • to conduct surveys or focus groups to receive your views of our properties and service delivery (if, where required, you separately provide your consent to this);
  • to respond to a specific "Information Request" from you about one of our hotels, resorts or residential properties and deal with any other enquiries, correspondence, concerns or complaints you have raised;
  • for marketing, advertising and promotional purposes, such as through one of our on-line promotions or on third party social networks, consistent with your preferences and applicable law;
  • if you become a Private Residence or Residence Club owner, to create an owner profile that is stored in our property management systems;
  • to analyze customer trends and insights; and
  • to operate our business, including for internal purposes such as auditing, data analysis, statistical and research purposes and troubleshooting to help us improve our services.

Occasionally we will combine information from a number of Guests and Owners to better understand trends and your expectations. When this occurs, all identifiers are removed and the aggregate, anonymized information cannot be linked to any specific individual or household.

On what basis do we use your personal information?

We use your personal information on the following basis:

  • to comply with legal and regulatory obligations, including financial reporting requirements imposed by government regulators and our auditors;
  • to enter into agreements with you, and to perform our agreement to provide services to you when you stay with us;
  • for legitimate business purposes – using your personal information helps us to operate and improve our business and minimise any disruption to the services that we may offer to you. It also allows us to make our communications with you more relevant and personalised to you, and to make your experience of our services more efficient and effective;
  • because you have given your consent – at times we may ask for your consent to allow us to use your personal information for one or more purposes. See the “Your rights” section for more information about the rights that you have if we process your information on the basis of your consent;
  • for purposes disclosed at the time you provide your personal information or as otherwise set forth in this Privacy Notice; or
  • for the establishment, exercise or defence of legal claims or proceedings.

How and from what sources is personal information collected?

For each of the categories of personal information and purposes described above, we gather information when you provide it to us, or interact with us directly, for example:

  • when you create a profile or sign in to access an existing profile on our website or App;
  • when you make a purchase through our website;
  • when you make a reservation online, by calling one of our Worldwide Reservation Offices or by contacting a particular hotel or resort directly; and
  • during your stay at a hotel, resort, Residence Club property or Private Residence, including information provided during check-in.

We also collect your personal information while monitoring our technology tools and services, including comment cards and email communications sent to and from Four Seasons.

We may also receive information about you from other sources, such as our business partners and publicly available sources, or from other members of your traveling party or other individuals. We combine information that we have about you from various sources, including the information that you have provided to us.

Finally, we may collect your photograph from publicly available sources so that we can recognize you in order to provide you with superior customer service.

Cookies and other data

We collect information automatically from you through the use of cookies, pixel tags and similar technologies, when you visit our website or use our mobile App or read our emails, and we may use third party partners to collect this device and usage information. For example, we collect information about how you use our website and mobile App, such as the pages you visit or links you click and if you use multiple devices, and information about the device you use, such as the IP address, device type, operating system, and a unique ID that allows us to uniquely identify a browser, mobile device or account (including, e.g., a persistent device identifier or AdID), and other such information. If permitted by your device settings, we and our third party providers may collect location data through GPS, Wi-Fi or other methods to personalize and enhance your online experience and to improve the effectiveness of our website, mobile App, offers, advertising, communications and customer service. We collect analytics data, or use third party analytics tools to help measure traffic and usage trends and to understand more about the demographics and behaviors of our users.

We, or our third party partners, may use the data collected through cookies and similar technologies to remember information so that you will not have to re-enter it during your visit or the next time you visit the website or mobile App; provide custom, personalized content and information; identify and contact you across multiple devices; provide and monitor the effectiveness of our website and mobile App and perform analytics; diagnose or fix technology problems; detect or prevent fraud or other harmful activities, and otherwise to plan for and enhance our online properties and services.

We may also use third party advertising companies to serve advertisements regarding goods and services that may interest you when you access and use our websites and mobile App. To serve such advertisements, these companies place or recognize a unique cookie on your browser (including through use of pixel tags).  For more information about our and our third party partners’ use of cookies and related technologies to collect information automatically, please see our Cookie Notice.

How do we protect personal information?

We use a variety of physical, technical and administrative security measures and technologies to help preserve the integrity and security of your personal information, consistent with applicable data protection and privacy laws.

We endeavor to protect the privacy of your account and other personal information that we hold in our records, but unfortunately, we cannot guarantee complete security. Unauthorized access or use, hardware or software failure, and other factors, may compromise the security of user information.  Also, while we endeavor to put adequate contractual protections in place, we cannot guarantee the security of any personal information in databases hosted by third parties.

It is important to note that any e-mail communication is not secure. This is a risk inherent in the use of e-mail. Please be aware of this when requesting information or sending forms to us by e-mail (for example, from the “Contact Us” section of our website). We recommend that you do not include any confidential information (e.g. credit card information) when using e-mail. For your protection, our e-mail responses to you will not include any sensitive personal information.

Finally, to be prudent, please be sure to always close your browsers when you are done using a form or the reservation site. Although the session will terminate after a short period of inactivity, it is best to close your browsers immediately upon completion, especially when using a public computer.

Will personal information be provided to third parties?

For each of the categories of personal information, sources of information and purposes described above, we may share certain of your personal information with:

  • other Four Seasons hotels and resorts, and managed properties (including Private Residences or Residence Club properties);
  • Four Seasons Residence Club Property Sales Specialists;
  • agents, contractors or third party service providers of Four Seasons who provide services to Four Seasons or on our behalf, including as needed to better serve your needs as a Guest or Owner;
  • others with your consent or at your direction;
  • escrow agents, third party lenders and loan-servicing agents;
  • a prospective buyer, investor or other third party in the event that we are involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of any business or assets or similar business transaction;
  • online advertising partners, analytics and search engine providers that assist Four Seasons in the improvement and optimisation of the website and our mobile App, or for advertising, analytics, attribution or research purposes (see our Cookie Notice to learn more);
  • our professional advisors and auditors; and
  • local or foreign regulators, governments, courts, law enforcement and national security authorities.

Where a third party engaged by Four Seasons processes personal information on our behalf, Four Seasons takes steps to contractually require these parties protect your personal information in a manner consistent with the principles articulated in this Privacy Notice.

In the case of third party residential property developers, please visit the particular developer's privacy notice to learn more about the personal information practices of the third-party developer.

If you have chosen to join a subscription list, please note that they are only used for internal purposes and we do not sell or rent our subscription lists to third parties for their direct marketing purposes.

If Four Seasons Hotels and Resorts suspects any unlawful activity is taking place, it may investigate and/or report its findings or suspicions to the police or other relevant law enforcement agency.

We may also disclose information as may be required by law or legal process, or if we reasonably believe such disclosure is necessary to comply with legal process or the reasonable requests of law enforcement or to exercise or protect the rights, property or personal safety of the Four Seasons Hotels and Resorts, our Guests or Owners, or others.

Transfers of your personal information outside your home country

Your personal information may be processed by Four Seasons and its third party suppliers anywhere in the world, including in countries where data privacy laws may not be equivalent to, or as protective as, the laws in your home country.

In particular, your personal information will be stored in your guest profile in our Central Reservation System located in Canada, and is available to all Four Seasons properties.

We will implement appropriate measures to ensure that your personal information remains protected and secure when it is transferred outside of your home country. These measures include data transfer agreements implementing standard data protection clauses. You can find out more about data transfer agreements here.

Your rights

Depending on applicable law, which may be determined by your country, region or state of residency, you may be able to exercise one or more of the following rights relating to our processing of your personal information. You may also have other rights under the laws of your jurisdiction of residence.

To protect your personal information, we may require that you prove your identity to us at the time your request is made. This may involve providing us with information which we hold on file about you (e.g. a home or business address), or we may require you to produce some form of photo or government issued identification.

Accessing, correcting or deleting your personal information

We understand that you may like to know what personal information we hold about you, or to correct or delete certain information we hold about you. We are happy to assist you with your request.

Four Seasons reserves the right to decline a request to access, correct or delete your personal information under certain circumstances as permitted by applicable law.  In particular, there may be a variety of legitimate business reasons why we may be unable to delete your personal information and where we are permitted to decline your request to delete your information.  

Right to decline marketing communications

If you do not wish to receive marketing communications from Four Seasons, you may indicate your wishes on your registration card when you stay with us or send an e-mail to: guest.historian@fourseasons.com. You will always have the ability to accept or decline any form of communication from Four Seasons. You may unsubscribe from electronic marketing communications at any time by selecting the “unsubscribe” link included in such communications. Please note that you may not be able to opt out of service-related communications (e.g., account verification, transactional communications, technical and security and notices).

Other rights

You may also be entitled to:

  • request the restriction of the processing of your personal information, or object to that processing;
  • opt out from the processing or disclosure of your personal information for direct marketing purposes;
  • withdraw your consent to the processing of your personal information (where Four Seasons is processing your personal information based on your consent); and
  • request the receipt or transmission to another organisation, in machine-readable form, of the personal information you have provided to Four Seasons.

Where you are given the option to share personal information with Four Seasons, you can always choose not to do so.

If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations.

This could mean that we are unable to perform the actions necessary to achieve the purposes of processing described above (see ‘How do we use your personal information?’) or that you are unable to make use of the services offered by us.

After you have chosen to withdraw your consent, Four Seasons may be able to continue to process your personal information to the extent required or otherwise permitted by law.

If at any time you wish to exercise any of these rights, you can do so by:

For hotel and resort Guests, contacting our Corporate Guest Historian:

Attention: Corporate Guest Historian
1165 Leslie Street
Suite 600
Toronto, Ontario M3C 2K8
Canada

 For Residence Club and Private Residence Owners:

  • via the Director of Residences at the Owner’s home property
  • via e-mail at guest.historian@fourseasons.com
  • if you live in California, toll-free at: 1-855-538-9044
  • via fax at 1 (416) 441-4676
  • via letter -

Attention: Corporate Guest Historian
1165 Leslie Street
Suite 600
Toronto, Ontario M3C 2K8
Canada

Alternatively, you can contact our Chief Privacy Officer via the details in the 'Contact us' section.

You may make a request through an authorised agent (such as a lawyer).  We may request evidence of their authority to act on your behalf.

Additional Notice for California Residents: Subject to certain exceptions, California residents may have the right to request access, deletion or to opt-out of personal information sales by submitting a request using the contact information above. You have the right not to be discriminated against if you choose to exercise those rights. We do not “sell” personal information to third parties, however, we do allow certain third party advertising networks and other third party businesses to collect your personal information directly from your browser or device through cookies and related technologies for advertising, attribution, analytics and research purposes. These third parties may use such personal information for their own purposes in accordance with their own privacy statements, which may include reselling this information to additional third parties. To opt-out or adjust your cookie preferences with regard to the collection of information for these purposes, please use our cookie consent tool available in our Cookie Notice to adjust your cookie preferences.  By visiting www.privacyrights.info, you can opt out from sales of this type of personal information by businesses that participate in the Digital Advertising Alliance’s (DAA) CCPA App-based Opt-Out Tool. You can also learn more about how you can manage cookies and tracking technologies in our Cookie Notice. California "Shine the Light" law (Civil Code Section §1798.83) provides certain rights to California residents that have an established business relationship with us with regard to the disclosure of certain types of personal information to third parties for their direct marketing purposes. We do not share your personal information with third parties for direct marketing purpose without consent.

How long is my personal information retained?

Your personal information will be stored for the period of time required or permitted by law in the jurisdiction of any hotel holding the information. This may involve retaining information following your stay. We will delete your personal information once it is no longer reasonably necessary for any of the purposes described in this Privacy Notice.

We will also keep your personal information where we need to do so in connection with a legal action or an investigation involving Four Seasons.

Any financial information Four Seasons retains will be protected under the terms of this Privacy Notice and, where financing is arranged in the United States, under the Financial Services Modernization Act.

How is personal information affected by business transactions and/or transfers?

Four Seasons manages properties on behalf of third party property owners. Four Seasons may disclose to such a property owner certain Guest or Owner information as needed to implement business transactions between the property and a particular Guest or Owner. All other personal information is considered to be proprietary to Four Seasons, and is not shared with property owners. If we cease to manage a particular property, guest information required to process pending reservations and information that is historically shared with the property owner is retained by the property owner. All other personal information remains with Four Seasons.

What laws apply to this notice?

Four Seasons Hotels Limited does business worldwide as Four Seasons Hotels and Resorts and is a Canadian corporation incorporated under the laws of the Province of Ontario, Canada. As such, Canada's Personal Information Protection and Electronic Documents Act applies to our company. We apply the requirements of this law (and any other applicable laws) to how we handle all personal information wherever received, and each property managed by Four Seasons also complies with the local privacy laws of the jurisdiction where it is located. All transfers of personal information between countries will be subject to the terms of this Privacy Notice and in compliance with applicable laws.

If you have additional questions regarding the law or if you feel we have not treated your personal information appropriately, you may contact The Privacy Commissioner of Canada at the following address:

The Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Quebec
K1A 1H3


Toll-free number: 1-800-282-1376

Phone: (819) 994-5444

Web site: https://www.priv.gc.ca/en/

E-mail: info@privcom.gc.ca

You may also have the right to complain to the local data privacy supervisory authority in your home country.

Third-Party Websites

Our websites and online services may include links to third party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any personal information practices of third party websites and online services or the practices of other third parties. To learn about the personal information practices of third parties, please visit their respective privacy notices.

Updates to this Privacy Notice

We will update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the "Last Updated" date at the beginning of this Privacy Notice and will provide any other form of notice as may be required by law. All changes shall be effective from the date of publication unless otherwise provided.

Contact us

If you have any questions or concerns regarding this Privacy Notice, please contact our Chief Privacy Officer by writing to the following address:

Chief Privacy Officer

Four Seasons Hotels and Resorts

1165 Leslie Street

Toronto, Ontario M3C 2K8

Canada

E-mail: privacy.officer@fourseasons.com

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