Last Updated: August 28, 2018
We will post any modifications or changes to the Policy on our Site. We reserve the right to modify the Policy at any time, so we encourage you to review it frequently. The “Last Updated” legend above indicates when this Policy was last changed. If we make any material change(s) to the Policy, we will post a notice on our Site/Services prior to such changes(s) taking effect.
Purposes of Processing
Why do we need your personal data?
We collect information about you in a range of forms, including personal data. We will only process your personal data in accordance with applicable data protection and privacy laws. If you are a subscriber, we need certain personal data in order to provide you with access to the Site/Services. If a user account was created for you will have been asked to agree to provide this information in order to access our services/products or view our content. This consent provides us with the legal basis we require under applicable law to process your data. You maintain the right to withdraw such consent at any time. If you do not agree to our use of your personal data in line with this Policy, please do not use our Site/Services.
Collecting Your Personal Data
We collect information about you in the following ways:
Information You Give Us. This includes:
the personal data you may provide when you register to use our Site/Services (including signing a Service Order) including your name, postal address, email address, telephone number, username and password;
the personal data you provide when you report a problem with our Site/Services or when we provide you with customer support;
the personal data you provide when you make a purchase thorough our Site/Services; any financial information we collect is used only to bill you for the Services you purchased and if you purchase by credit card, this information may be forwarded to your credit card provider; and
the personal data you provide when you correspond with us by phone, email or otherwise.
Information from Social Networking Sites.
Our Site/Services include(s) interfaces that allow you to connect with social networking sites (each a “SNS”). If you connect to a SNS through our Site/Services, you authorize us to access, use and store the information that you agreed the SNS could provide to us based on your settings on that SNS. We will access, use and store that information in accordance with this Policy. You can revoke our access to the information you provide in this way at any time by amending the appropriate settings from within your account settings on the applicable SNS.
Information Automatically Collected. We automatically log information about you and your computer or mobile device when you access our Site/Services. For example, when visiting our Site/Services, we log your computer or mobile device operating system name and version, manufacturer and model, browser type, browser language, screen resolution, the website you visited before browsing to our Site/Services, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our Site/Services. We collect this information about you using cookies. Please refer to the sections on cookies, Flash Technology and Pixel Tags below.
Automated Decision Making and Profiling.
We do not use your personal data for the purposes of automated decision-making. However, we may do so in order to fulfil obligations imposed by law, in which case we will inform you of any such processing and provide you with an opportunity to object.
Cookies we use
Our Site/Services use the following types of cookies for the purposes set out below:
Type of Cookie
These cookies are essential to provide you with services available through our Site/Services and to enable you to use some of its features. For example, they allow you to log in to secure areas of our Site/Services and help the content of the pages you request load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
These cookies allow our Site/Services to remember choices you make when you use our Site/Services, such as remembering your login details. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Site/Services.
Analytics and Performance Cookies
These cookies are used to collect information about traffic to our Site/Services and how users use our Site/Services. The information gathered does not identify any individual visitor. The information is aggregated and anonymous. It includes the number of visitors to our Site/Services, the websites that referred them to our Site/Services, the pages they visited on our Site/Services, what time of day they visited our Site/Services, whether they have visited our Site/Services before, and other similar information. We use this information to help operate our Site/Services more efficiently, to gather broad demographic information and to monitor the level of activity on our Site/Services.
We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Site/Services work. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies
You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html.
You can prevent the use of Google Analytics relating to your use of [our Site/Services] by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.
Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com/uk.
If you do not accept our cookies, you may experience some inconvenience in your use of our Site/Services. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Site/Services.
We may also use pixel tags (which are also known as web beacons and clear GIFs) on our Site/Services to track the actions of users on our Site/Services. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages. Pixel tags measure the success of our marketing campaigns and compile statistics about usage of the Site/Services, so that we can manage our content more effectively. The information we collect using pixel tags is not linked to our users’ personal data.
Website Server Logs
When you visit our website, we may automatically collect information to administer the website and analyze its usage. Examples of information we may collect include:
Your Internet protocol address.
The kind of browser or computer you use.
Number of links you click within the website.
State or country from which you accessed the website.
Date and time of your visit.
Name of your Internet service provider.
Web page from which you linked to our website.
Pages you viewed on the website.
Email messages are not secure. We are not responsible for the security or confidentiality of communications sent to us via Internet email messages. Our security software does not encrypt email messages. Email messages traveling through the Internet are potentially subject to viewing, alteration and copying by anyone on the Internet. Be cautious when submitting personal or financial information via email. Send confidential information through the postal service or use the telephone to speak directly to our employees.
You should not respond to emails from anyone that request validation of personal information or link to websites requesting validation of personal information.
Using Your Personal Data
We may use your personal data as follows:
to operate, maintain, and improve our Site/Services;
to manage your account, including to communicate with you regarding your account, if you have an account on our Site/Services;
to respond to your comments and questions and to provide customer service;
to send information including technical notices, updates, security alerts, and support and administrative messages;
with your consent, to send you marketing e-mails about upcoming promotions, and other news, including information about products and services offered by us and our affiliates. You may opt-out of receiving such information at any time: such marketing emails tell you how to “opt-out.” Please note, even if you opt out of receiving marketing emails, we may still send you non-marketing emails. Non-marketing emails include emails about your account with us (if you have one) and our business dealings with you;
to process payments you make for our Site/Services;
as we believe necessary or appropriate (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others; and
as described in the “Sharing of your Personal Data” section below.
Sharing Your Personal Data
We may share your personal data as follows:
Third Parties Designated by You. We may share your personal data with third parties where you have provided your consent to do so.
Our Third Party Service Providers. We may share your personal data with our third party service providers who provide services such as data analysis, payment processing, information technology and related infrastructure provision, customer service, email delivery, auditing and other similar services. These third parties are only permitted to use your personal data to the extent necessary to enable them to provide their services to us. They are required to follow our express instructions and to comply with appropriate confidentiality provisions and security measures to protect your personal data.
Affiliates. We may share some or all of your personal data with our affiliates, in which case we will require our affiliates to comply with this Policy. In particular, you may let us share personal data with our affiliates where you wish to receive marketing communications from them
Corporate Restructuring. We may share personal data when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.
Other Disclosures. We may share personal data as we believe necessary or appropriate: (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities to meet national security or law enforcement requirements; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others.
When we use the term “anonymous data,” we are referring to data and information that does not permit you to be identified or identifiable, either alone or when combined with any other information available to a third party.
We may create anonymous data from the personal data we receive about you and other individuals whose personal data we collect. Anonymous data might include analytics information and information collected by us using cookies. We make personal data into anonymous data by excluding information (such as your name) that makes the data personally identifiable to you. We use this anonymous data to analyses usage patterns in order to make improvements to our Site/Services.
Third Party Sites
Our Site/Services may contain links to third party websites and features. This Policy does not cover the privacy practices of such third parties. These third parties have their own privacy policies and we do not accept any responsibility or liability for their websites, features or policies. Please read their privacy policies before you submit any data to them.
We seek to use reasonable organizational, technical and administrative measures to protect personal data within our organization. We maintain physical, electronic and procedural safeguards to guard your nonpublic personal information. Our operational and data processing systems are contained in a secure environment and that environment is access-controlled.
To secure sensitive communications between your computer and our web servers, we have implemented digital certificates and encryption. We use secure sockets layer, SSL, security protocol to protect all exchanges of information via our website pages that are considered private or confidential.
We use various authentication technologies, including passwords, to authenticate visitors to the portions of our website that may allow access to private or confidential information. We have implemented other security controls such as firewalls, and intrusion prevention to protect our systems and networks and your information. Our security systems constantly monitor the website server to ensure your accounts are safe and secure.
Unfortunately, no transmission or storage system can be guaranteed to be completely secure, and transmission of information via the internet is not completely 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 any account you might have with us has been compromised), please immediately notify us of the problem by contacting us using the details in Section 17 below.
We will only retain your personal data as long reasonably required for you to use the Site and/or to provide you with the Services [until you close your account/cancel your subscription] unless a longer retention period is required or permitted by law (for example for regulatory purposes).
Sensitive Personal Data
Subject to the following paragraph, we ask that you not send us, and you not disclose, any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Site/Services or otherwise to us.
If you send or disclose any sensitive personal data to us when you submit user generated content to our Site/Services, you consent to our processing and use of such sensitive personal data in accordance with this Policy. If you do not consent to our processing and use of such sensitive personal data, you must not submit such user generated content to our Site/Services.
Opt-out. You may contact us anytime to opt-out of: (i) direct marketing communications; (ii) automated decision-making and/or profiling; (iii) our collection of sensitive personal data; (iv) any new processing of your personal data that we may carry out beyond the original purpose; or (v) the transfer of your personal data outside the EEA. Please note that your use of some of the Site/Services may be ineffective upon opt-out. If you do not wish to have your contact information used by “The Hotel” you can opt-out by sending us an email stating your request to [email protected]. If we have sent you a promotional email, the email will have an “unsubscribe” feature that will allow you to opt-out of receiving future email distributions.
If you are a California resident, California law permits you to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to [email protected].
Access. You may access the information we hold about you at any time via your profile/account or by contacting us directly. We will provide you with the means to ensure that personal information in your account file is correct and current. You may review this information by contacting us by sending an email to [email protected]
You can also contact us to update or correct any inaccuracies in your personal data.
Your personal data is portable – i.e. you to have the flexibility to move your data to other service providers as you wish.
Erase and forget. In certain situations, for example when the information we hold about you is no longer relevant or is incorrect, you can request that we erase your data.
If you wish to exercise any of these rights, please contact us using the details in Section 17 below. In your request, please make clear: (i) what personal data is concerned; and (ii) which of the above rights you would like to enforce. For your protection, we may only implement requests with respect to 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 implementing your request. We will try to comply with your request as soon as reasonably practicable and in any event, within one month of your request. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.
We are committed to resolve any complaints about our collection or use of your personal data. If you would like to make a complaint regarding this Policy or our practices in relation to your personal data, please contact us at: [email protected]. We will reply to your complaint as soon as we can and in any event, within 45 days. We hope to resolve any complaint brought to our attention, however if you feel that your complaint has not been adequately resolved, you reserve the right to contact your local data protection supervisory authority.
GDPR COMPLIANCE. This section provides additional information applicable to the processing of personal data of individuals in the European Union.
1. Who we are: For the purpose of applicable data protection legislation, the data controller of your personal data is the general manager at hotel address.
2. PERSONAL DATA. As used in this Policy, “personal data” is as defined in the UK Data Protection Act 1998/the European Data Protection Directive 95/46/EC/General Data Protection Regulation 2018 and any successor legislation, this includes any information which, either alone or in combination with other information we hold about you, identifies you as an individual, including, for example, your name, postal address, email address and telephone number.
3. International Data Transfer. Your information, including personal data that we collect from you, may be transferred to, stored at and processed by us and our affiliates and other third parties outside the country in which you reside, including, but not limited to the United States, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. By using our Site/Services, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.
4. OTHER PERSONAL DATA WE COLLECT. If you are contacted by “The Hotel” in connection with our data collection process in the EU, we collect certain personal information, after you’ve consented to us doing so. Upon your consent, we may share that information with customers by including your information in certain Hotel products and services. See Section 14 for your ongoing rights about this personal information.
We welcome your comments or questions about this Policy. If you have questions regarding our Policy or its implementation, please contact us at [email protected] or send your comments to:
“SCP Colorado Springs”
Attention: General Manager
2850 South Circle Dr.
Colorado Springs, Colorado 80906