Privacy Policy v0.5 Oktober 2024

Sonesta Sint Maarten

Sonesta Sint Maarten provides this Privacy Policy describing important information about how we collect, use, and disclose your personal data in the following circumstances:

• Through the websites or mobile applications we own and control that link to this Privacy Policy (the “Online Services”),
• Through the social media pages we control, marketing emails that we send, and other direct marketing activities (“Marketing Activities”),
• Through our interaction with business contacts in the context of their relationship with us (“Business Contact Activities”),
• When you visit our property and through other in-person interactions with you (“Offline Activities”).

When we use the term “Services” in this Privacy Policy, we collectively refer to the Online Services, Marketing Activities and Offline Activities.

When we use the term “guests” in this Privacy Policy, we mean the users of and visitors to the Services.

When we use the term “personal data” we mean any information that identifies an individual person or reasonably relates to an identifiable individual.

What Personal Data do we collect

1. Personal data

We collect personal data about our guests so that we can provide an experience that is responsive to your needs and to enhance our offerings to you and our other customers, including:

• Name
• Postal address
• Email addresses
• Telephone numbers
• IP Address and other online identifiers
• Credit card information and other payment data
• Financial information, in limited circumstances
• Account information, such as username and password
• Gender or gender expression
• Health information, from guests with particular health concerns that they have shared with us
• Lifestyle information, such as room preferences and other information necessary to fulfil special requests (e.g., medical conditions that require room accommodations)
• Date of birth
• Nationality, passport, visa, or other government-issued identification information where necessary only, for example if access to nationality-based rates has been granted
• Job title and employment affiliations
• Employer details
• Travel itinerary, tour group, or activity data
• Guest preferences and personalized data, such as your communications and language preferences, travel habits and preferences, food and beverage preferences, interests, activities, hobbies, prior stays or interactions, goods and services purchased, special service and amenity requests, and important dates (such as birthdays, anniversaries and special occasions)
• Social media account ID, profile photo, and other data publicly available, or data made available by linking your social media and loyalty accounts
• Information about family members and companions, such as names and age of children
• Images, video, and audio data via CCTV cameras and security personnel body cameras
• Geolocation information

2. Other Data

We collect other data about you, including:

• Information regarding your use of our Online Services, including browser and device data, and data collected through cookies, pixel tags, and other technologies (these practices are more fully described below in the “Cookie Notice” section)
• Demographic data and other data provided by you
• Aggregated data relating to your stays

How we collect Personal Data

1. Online Services and Marketing Activities

We collect Personal Data through our Online Services and Marketing Activities when you:

• Research and book a reservation
• Purchase products or services
• Make a customer service request
• Respond to a survey
• Subscribe to our newsletter
• Register for our loyalty program
• Update your contact information
• Participate in a competition, promotional activity, or sweepstakes
• Provide a testimonial, story, review, or comment
• “Like,” “Follow,” or otherwise connect with or post to one of our social media pages
• Interact with an email we send

2. Offline Activities

We collect Personal Data during your visits to properties we own, operate, franchise, or license, and through other in-person interactions when you:

• Purchase or use on-site products and services, such as restaurants and bars, fitness centers, tours, and concierge services
• Attend promotional events that we host or in which we participate, or when you provide your personal data to facilitate an event.

3. Business Partners

We collect Personal Data from companies with whom we partner to provide you with products, services, or offers based upon your experiences at our properties or that may be of interest to you. These business partners are independent from Sonesta. Examples of our business partners include:

• Owners, franchisees, and licensees
• On-property retail and food and beverage outlets
• Travel agents and tour operators
• Time share partners
• Rental car providers
• Travel booking platforms

4. Other Sources

We collect personal data from other sources, such as public databases, joint marketing partners, Guest devices that are connected to Wi-Fi we provide, and other third parties.

5. 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 at one of our properties that you visit.

6. Physical & Mobile Location-Based Services

We collect personal data if you download one of our mobile applications (for example, we may collect the precise physical location of your device). We collect this data if you opt in through the app, 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 will continue to collect location data when you are in or near a participating property until you log off or close application, or if you use your device’s setting to disable location capabilities for the app.

Why We Collect Personal Data

We collect the personal data above about our Guests so that we can provide an experience that is responsive to your needs and to enhance our offerings to you and our other customers. More specifically, we use the information in connection with the following:

Our business transactions with you, including, but not limited to:

• Fulfilling bookings
• Entering into a contract with you
• Responding to your inquiries and fulfilling your requests
• Sending administrative information to you (for example, information regarding the Services or an event you are attending)
• Completing and fulfilling any purchases or requests for services

Our legitimate business interests, including, but not limited to:

• Providing any other specific products, services, and information you request from us (such as participation in our loyalty programs)
• Providing you our newsletter, surveys, and other marketing and informational materials regarding our properties, products, and services (subject to your opt out right described in the “Opt Out” section below)
• Personalizing your experience on the Services by presenting products and offers tailored to you
• Allowing you to participate in sweepstakes, contests, and similar promotions, and to administer these activities (each of which may have additional rules and could contain additional information about how we process your personal data)
• Facilitating social sharing functionalities of your social media accounts
• Carrying out data analysis, audits, fraud monitoring and prevention, internal quality assurance, developing new products, enhancing, improving or modifying our Services, identifying usage trends, auditing use and functionality of our Services, helping enforce compliance with our Terms of Use, helping protect our Services, determining the effectiveness of our promotional campaigns, and operating and expanding our business activities
• Allowing you to send messages to a friend through the Services. By using this functionality, you are telling us that you are entitled to use and provide us with your friend’s name and email address
• Fulfilling any other purpose for which you provide your personal data or which we disclose to you at the time of disclosure

Any consent you may have provided, including, but not limited to accommodating special requests due to health conditions.

We will make it clear to you in advance that we are relying on your consent (for example, when you sign up to our mailing list), and you have the right to decline to provide your consent and, if consent is provided, to withdraw your consent at any time

As necessary or appropriate for legal reasons, including, but not limited to:

• To comply with our legal obligations
• To comply with legal process
• To respond to requests from public and government authorities, including those outside your country of residence
• To enforce our terms and conditions
• To protect our operations or those of any of our affiliates and other third parties
• To protect our rights, privacy, safety, or property, or that of our affiliates, you, or other third parties, including to support and enhance our data security
• To allow us to pursue available remedies or limit damages we, our affiliates, or other third parties, may sustain

How We Share and Disclose Personal Data

1. To Whom We Disclose Personal Data for a Business Purpose

In the course of processing your personal data in connection with fulfilling bookings and providing other products and services you obtain from us, it may be necessary to transfer your personal data to:

• Our affiliates (for example, we share loyalty program data)
• Our owners, franchisees, and licensees (for example, we share reservation data)
• Payment processors and/or third-party service providers located in the United States and throughout the world for the purposes outlined in this Privacy Notice
• Business partners, sponsors, and other third parties

Unless otherwise precluded or governed by legal requirements, we do not grant permission to any of our affiliates, property owners, franchisees, licensees, or third-party service providers that may receive your information to use such information independent of use in connection with our products and services, consistent with this policy.

Except for the disclosure noted above regarding affiliates, properties, franchises and licenses, payment processors and third-party service providers, and except as disclosed below, our practice is to not provide access to, sell, rent, or otherwise give physical possession of your personal data to other parties.

2. When We Disclose Your Personal Data

Situations in which we may disclose your personal data, any communications sent to or received from you, and other information that we may have related to you, are:

• When we have received your consent to do so
• When a hotel or other property leaves the Sonesta system and access to your personal data is necessary to facilitate business operations or meet contractual obligations
• To comply with legal or regulatory requirements or obligations in accordance with applicable law, including pursuant to a court order, subpoena, discovery, investigation, or similar action
• In case of emergency, if we believe it helpful in order to safeguard the life, health, or property of an individual
• If reasonably necessary to protect or enforce our property and rights, including to prevent, investigate, identify persons or organizations potentially involved in, or take any action regarding suspected fraud, violations of our terms of service, or activity that appears to us to be illegal or may expose us to legal liability, and
• In the event we merge with, or sell, or have a change of control of all or part of our business to a third party, to the acquirer of such business.

3. Limiting Information Sharing

If information is shared as mentioned above, we reasonably seek to limit the scope of information that is furnished to the amount necessary for the specific circumstances.

Cookie Notice

We collect other data using cookies and related data collection technologies (“Cookies”) to provide our Online Services engage in Marketing Activities, gather information when users navigate through our websites to enhance and personalize the experience, to understand usage patterns, and to improve our websites, products, and Services.

Cookies on our websites are generally divided into the following categories:

• Essential Cookies: These cookies are strictly necessary to provide you with services available through our Online Services and to use some of their features, such as access to secure areas. Because these cookies are strictly necessary to deliver the Online Services, you cannot refuse them without impacting how our Online Services function.
• Performance and Functionality Cookies: These cookies are used to enhance the performance and functionality of our Online Services but are non-essential to their use. However, without these cookies, certain functionality may become unavailable.
• Analytics and Customization Cookies: These cookies collect information that is used to help us understand how our Online Services are being used or how effective our marketing campaigns are, or to help us customize our Online Services for you in order to enhance your experience.
• Targeting Cookies: These cookies record your visit to our Online Services, the pages you have visited and the links you have followed to recognize you as a previous visitor and to track your activity on our websites and other websites you visit. These cookies qualify as persistent cookies, because they remain on your device for us to use during a next visit to our websites. You can delete these cookies via your browser settings. See below for further details on how you can control third-party targeting cookies.
• Pixels & Beacons: These technologies count how many people visit certain web pages. Information collected from invisible pixels is used and reported in the aggregate and does not contain personal data. We may use this information to improve marketing programs and content.

We also allow third parties to use Cookies on our Online Services to collect information about your online activities over time and across different websites you visit. This information is used to provide advertising tailored to your interests on websites you visit, also known as interest-based advertising, and to analyze the effectiveness of such advertising.

How to control Cookies:

• You can review your Internet browser settings, typically under the sections “Help” or “Internet Options,” to exercise choices you have for certain Cookies. If you disable or delete certain Cookies in your settings, you may not be able to use features of the Online Services.
• To learn more about the use of Cookies by Google for analytics and to exercise choice regarding those Cookies, please visit the Google Analytics Opt-out Browser Add-on.
• We support the Self-Regulatory Principles for Online Behavioral Advertising of the Digital Advertising Alliance (“DAA”). To learn more about certain third-party Cookies used for interest-based advertising, including through cross-device tracking, and to exercise certain choices regarding such cookies, please visit the Digital Advertising Alliance, Network Advertising Initiative, Digital Advertising Alliance-Canada, European Interactive Digital Advertising Alliance or your device settings if you have the DAA or other mobile app.

The opt-outs described above are device- and browser-specific and may not work on all devices. If you choose to opt-out through any of these opt-out tools, this does not mean you will cease to see advertising. Rather, the ads you see will just not be based on your interests.

Other Information

1. Links to Other Web Sites

In some cases, our Online Services contain links to websites operated and maintained by third parties over which we have no control. When you connect to such website, you leave our Online Services. You should always read the privacy policy on these sites prior to transmitting any personal data since we cannot verify or be responsible for information not maintained by us. You connect to these sites at your own risk.

2. Social Media Sites

We are not responsible for the collection, usage, and disclosure policies and practices (including data security) of other organizations, such as Facebook, Apple, Google, Microsoft, RIM, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including any personal data you disclose to other organizations through or in connection with our mobile applications or our Marketing Activities.

3. Protecting Minor Children

Except as noted below, we do not seek to obtain nor do we wish to receive personal data directly from minors; however, we cannot always determine the age of persons who access and use our Online Services. If a minor (as defined by applicable law) provides us with their data without parental or guardian consent, we encourage the parent or guardian to contact us to have this information removed and to unsubscribe the minor from our future marketing communications.

Exceptions to this are:

• The names and ages of minors staying in rooms under reservations booked by an adult, whose names are recorded
• Our properties have, from time-to-time, programs and services directed at children, such as our “Kids Club” and similar supervised children’s services, for which email, contact information, age, and relevant personal information may be acquired from minors (such minimum age subject to appropriate adjustment in each jurisdiction to comply with law)

4. Information Provided on Someone Else’s Behalf

If you provide us with information about someone else, please ensure you have the person’s permission to do so for the purposes detailed in this Privacy Notice.

Communications, Opt In, and Opt Out

1. Our Intention for Communications

Our intention is that you should only receive email communications that you request, or that you will find useful. We may periodically contact you to provide information on:

• Upcoming or past reservations
• Travel Pass account information
• General hotel or corporate informational updates
• To ask for your feedback on our service

2. Communication Methods

This communication is typically via email, though it may be by phone or direct mail (particularly with respect to upcoming reservations). We may also send promotional emails with special offers that may be of interest to you (unless you have opted out).

3. Opting In and Out

Through various means, you may opt in or sign up to receive promotional emails from us. All our promotional emails give you the option to opt out at any time by clicking on a link at the bottom of the email.

Security

We seek to take steps to protect the information you provide us from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. We have implemented physical, electronic, and managerial procedures to help safeguard and secure your information from loss, misuse, unauthorized access or disclosure, alteration, or destruction. Unfortunately, no security system is 100% secure, thus we cannot guarantee the security of all information you provide to us via the Services.

Policy Changes

At times our Privacy Notice may be changed and any updates will be posted to this site. If material changes are made to this Notice, we will post a notice to the revised policy on the homepage of this site for at least thirty (30) days. Any changes that are made will go into effect when posted on the site and they will apply to all users of our Services. We encourage you to check this policy periodically for updates.

Contact Us

If you have any questions about this Policy, or any concerns or complaints with regard to the administration of the Policy, please contact us by any of the following means:

by mailing a written description of your concern or complaint to:

Sonesta Sint Maarten
attn General Manager
1 Rhine Road
Maho Beach Sint Maarten

by emailing to privacyinquiries@sonestastmaarten.com