LIVINGWELL PRIVACY STATEMENT
LivingWell recognises that your personal privacy is an important issue and we are committed to safeguarding your privacy when you use our web site. Any information that we collect about you will be used in accordance with the Data Protection Act 1998. If you have any queries regarding our privacy policies please contact us (details are on our contact us page).
Information collected. In order to use our web site you are not required to register or provide any information about yourself. We may on occasion ask you to provide some limited personal information about yourself, such as your name, address and e-mail to enable you to participate in competitions or surveys. We may also collect information about how you use this site; any such information is only used in aggregate form and cannot be used to identify you personally.
Use and disclosure of personal information We will hold your information for the purpose of administering your account. We may from time to time contact you using the information you provide us with for the purpose of informing you of offers and product updates. We will not pass your details on to 3rd parties. We may also disclose information to the police or other official bodies, as required by law, to assist them with their official investigations.
How we store information. Information is stored in a physically and electronically secure data centre. Direct access to this database is restricted to authorised LivingWell staff and their appointed agents. LivingWell has taken every reasonable step to ensure that your information is held securely at all times and that access to it is closely monitored.
Last Updated: May 2015
At Hilton Worldwide, we strive to deliver outstanding products, services, and experiences around the world. We value your business and, more importantly, your loyalty. We recognize that privacy is an important issue. We have developed this Global Privacy Statement (“Statement”) to explain the practices of Hilton Worldwide, Inc. and its direct and indirect subsidiaries (collectively, “Hilton,” “we,” or “us”) regarding the personal information we collect from you or about you whether on this site, through written or verbal communications with us, information collected when you visit one of our properties, or from other sources.
Also, 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.
Personal Information We Collect
At every touch point or guest interaction, and in conducting every aspect of our business, we may collect personal information. This personal information may include: your contact information; information related to your reservation, stay or visit to a property; participation in a membership or loyalty program; participation in a sweepstakes or marketing program (even if you do not stay at one of our hotels); information related to the purchase and receipt of products or services; personal characteristics, nationality, income, passport number and date and place of issue; travel history; payment information; guest preferences; marketing and communication preferences; information about vehicles you may bring onto our properties; reviews and opinions about our Portfolio of Brands or properties (if they are identified or associated with you); frequent flyer or travel partner program affiliation and member number; hotel, airline and rental car packages booked; groups with which you are associated for stays at hotels; information needed to administer the HHonors program and profiles, including transaction and correspondence details; information provided on membership and account applications; information necessary to allow you to take advantage of our HHonors App functionality (where available) which allows you to check-in on your mobile device, select your room, receive a room key on your mobile device, and check out on your mobile device; and other types of information that you choose to provide to us or that we may obtain from third parties. We may also record details on joint travelers, including their names and frequent flyer numbers, and the age of the driver of the rental car. We may also collect and keep information and records related to conversations, including recording or monitoring customer service calls.
In addition we collect other personal information in certain cases, such as:
- HHonors: When you enroll in our HHonors program, we will also ask you to indicate whether you are at least 18 years old, and we will record an HHonors number and password for you. When you manage your profile online, you have the opportunity to provide additional information about your preferred airline partners and your loyalty program account numbers with them, your room type preferences, your language preferences, your credit card account(s), your email subscription preferences for receiving news, offers and information from us, and to create a User ID and password. Also, when you book a Rewards Reservation or purchase HHonors Points online, we may ask for additional specific account information such as corporate account number, group or convention code, travel agent number or AAA number.
- Surveys: We may request demographic data or other personal information in customer surveys.
- On-property Collection: Local laws may require that we collect additional personal information during registration/check-in at our properties. We may also use closed circuit television and other security measures at our properties that may capture or record images of guests, visitors in public areas and information related to your location while on our properties via keycards and other technologies. We may also use other technologies that record sound or video to protect our staff. In addition, we may collect personal information in connection with on-property services, such as concierge services, health clubs, spas, activities, child care services, equipment rental, and our Digital Key functionality in the HHonors App (where available).
- Event Profiles: If you plan an event with us, we collect meeting and event specifications, the date of the event, number of guests, details of the guest rooms, and, for corporate events, information on your organization (name, annual budget, and number of sponsored events per year). We also collect information about the guests that are a part of your group or event. If you visit us as part of a group, we may have personal information about you provided to us by the group and may market to you as a result of your stay with a group or attendance at an event. If you visit us as part of an event, we may share personal information about you with the event planners so they may include you as part of the event. If you are an event planner we may also share information about your event with third-party service providers who may market event services to you.
- Hilton Grand Vacations Timeshare: If you submit an online “pre-application” for timeshare or if you submit a reservation or information request online, or participate in an online “click-to-chat” type feature, we may ask you to provide your annual income range or reservation information. If you attend a Hilton Grand Vacations event, or preview tour, or enter a sweepstakes, we may ask you to provide information about your family composition, travel preferences, frequency of travel and other vacation history information. If you register for an online account with Hilton Grand Vacations Club and/or The Hilton Club, or other club products or programs introduced from time to time, we may also ask you to provide your member or reservation number, and security codes. If you finance the purchase of a timeshare, we may collect loan application and servicing information.
- Online Accounts: When you register an online account (e.g., as a member of Hilton Grand Vacations Club and/or The Hilton Club, or another club product or program), we also ask you to select a username and password.
- Social Media: If you choose to participate in Hilton-sponsored social media activities or offerings, we may collect certain information from your social media account consistent with your settings within the social media service, such as location, check-ins, activities, interests, photos, status updates and friend list. You should understand that you may be subject to the terms and conditions and any privacy policies of the social media site and that Hilton is not responsible for your activities on social media sites.
- Forward-to-a-Friend: From time to time, we may offer a feature that allows you to send an electronic postcard or otherwise share a message with a friend, whether via the Internet, a stand-alone kiosk or mobile. If you choose to do so, we will ask you for the recipient’s name and email address, along with the text of any message you choose to include, or you may be able to use a pre-populated message. By using this feature, you represent that you are entitled to use and provide us with the recipient’s name and email address for this purpose.
- Franchise Opportunities: If you are interested in obtaining more information about franchise opportunities, we may also collect information about your specific interests, such as brand, type of ownership and information about your property type such as current ownership, size of parcel, location of parcel, number of rooms, height limitation and time frame for planning or acquisition.
- Employment Applications: If you choose to apply online for employment with Hilton, please see our Applicant Privacy Notice.
- WMBE Suppliers: If your U.S. company is a Women’s/Minority Business Enterprise interested in participating in Hilton’s Supplier Diversity Program, you may complete the Supplier Diversity Profile Application Form online. If you choose to apply, you will be asked to provide information about your company and its principals, including the principal’s name, address, email address, ethnicity, contact person’s name and email address, company’s tax identification number and legal structure, and evidence of Women’s/Minority Business Enterprise certification.
Personal Information We Collect from Third Parties
In addition to the information we collect from you directly, we may also infer information about you based on the information you provide to us or from Other Information we receive. (See below for more details about “Other Information.”) We may also collect information about you from third parties, including information from our airline, credit card, and other partners, information from social media sites consistent with your settings on such sites, such as social media sign-on programs, and from third-party sources. We may append this information to the information we have on file for you and share it with others consistent with this Statement.
Use of Personal Information Collected About You
We use your personal information to provide the services you request from Hilton, or which are part of a program you have joined or a purchase you have made. We also use your personal information to provide you with information about meeting and event planning and access to specific account information for administrative purposes. In addition, we may use your information to: improve Hilton’s services; provide you with the expected level of hospitality; ensure our site, products and services are of interest to you; process enrollments and applications; and facilitate collections. We also use the information to provide or offer you newsletters, promotions and featured specials, other marketing communications, product or service awareness marketing, to conduct surveys, sweepstakes, prize draws, and other contests, and in connection with our HHonors App and Digital Key functionality where available). We may provide these communications online, via email, telephone, mobile/text messaging (including SMS and MMS) and postal mail. We may also aggregate your personal information with data from third-party sources for purposes of data hygiene and analytics.
eFolio Program: In order to provide the most efficient service, we encourage you to receive your hotel bill via email (“eFolio”). All guests will be automatically enrolled in this program. However, you can choose to receive a paper receipt by making such request upon check in or at any time during your stay prior to your departure date. The email address you provided upon making your reservation, or if you are an HHonors member and did not change your email address upon making your reservation, your email address of record, will be used to send you your eFolio. If you would like your eFolio to be sent to a different email address, you can make that request upon check-in or at any time during your stay prior to your departure date. Further, we do not have any mechanism for verifying your email address, so it is your responsibility to ensure that we have the correct (and preferred) email address for you. If you make a reservation for another person and use your email address, your email address will be used to provide their receipt.
How We Share Personal Information
As a global company, we endeavor to provide you with the same level of service that you have come to expect at Hilton whether you are in San Francisco, London or Tokyo. To provide this service, we may share your personal information among members of the Hilton Worldwide Portfolio of Brands, including Hilton Grand Vacations, franchisees, managed hotels, or service providers that may be located in countries outside your own. Although the data protection laws of these various countries may not be as comprehensive as those in your own country, Hilton will take appropriate steps to ensure that your personal information is handled as described in this Statement.
- Hilton Worldwide Portfolio of Brands: We may share personal information with other companies within the Hilton Worldwide Portfolio of Brands, including Hilton Grand Vacations, that may jointly use the personal information for the purposes described above. Hilton Worldwide, Inc. is the party responsible for the management of the jointly used personal information.
- Franchised Hotels, Managed Hotels, Timeshare and Fractional Resorts: We may share personal information with owners and operators of franchised hotels, owners of hotels that we manage but do not own, and timeshare or fractional ownership resorts in order to provide you with services. In addition, when we cease managing a hotel that we do not own, we may provide the hotel’s owner with limited information about past or future guests of that hotel.
- Electronic Billing Program: If you participate in a corporate electronic billing program or the eFolio program, billing information will be shared with the credit card provider and if you use a corporate credit card, possibly, your employer.
- Group Events or Meetings: If you visit Hilton as part of a group event or meeting, information collected for meeting and event planning may be shared with the organizers of those meetings and events, and, where appropriate, guests who organize or participate in the meeting or event.
- Business Partners: From time to time we may partner with other companies to provide products or services and may share your information with our business partners to provide those products or services to you. For example, we may help to arrange rental car or other services from our business partners, and share personal information with our business partners in order to provide those services. If you are an HHonors member, we may share your personal information with our business partners in order to credit you with mileage or other benefits earned through your participation in the HHonors program.
- Co-Sponsors of Promotions: We also may co-sponsor promotions, sweepstakes, prize draws, competitions or contests with other companies, or we may provide prizes for sweepstakes and contests sponsored by other companies. If you enter one of these sweepstakes or contests, we may share your information with our co-sponsor or the third-party sponsor.
- On-property Services: We may share personal information with providers of on-property services that provide services such as concierge services, spa treatments, golf, or dining experiences.
- Service Providers: We rely on service providers to provide certain products and services, such as to facilitate administrative functions and information technology operations, credit card billing, reservations services, administering the HHonors program, the Hilton Grand Vacations Club and The Hilton Club program, providing services in connection with our websites, including airline and rental car packages; communicating news and delivering promotional and transactional materials via email, direct mail, and online and mobile advertising; processing credit card transactions, data hygiene and enhancement services; professional services such as accounting, auditing and legal advice; investigating accident reports; processing insurance claims; and administering sweepstakes, prize draws, competitions and customer surveys. Hilton will disclose personal information to service providers as appropriate.
- Business Transactions: As we develop our business, we might sell, buy, restructure or reorganize businesses or assets. In the event of a merger, consolidation, sale, liquidation or transfer of assets, Hilton may, in its sole and absolute discretion, transfer, sell or assign information collected, including, without limitation, Other Information and personal information, to one or more affiliated or unaffiliated third parties.
- Telemarketing: If you stay at a Hilton Hotel or are an HHonors member, we may share your telephone number among our Portfolio of Brands, including Hilton Grand Vacations, for purposes of telemarketing. We may also receive your telephone number from our partners or from other sources, which we may use for telemarketing purposes.
- Other: In addition, Hilton may disclose personal information in order to: (i) comply with applicable laws, (ii) respond to governmental inquiries or requests from public authorities, (iii) comply with valid legal process, (iv) protect the rights, privacy, safety or property of Hilton, site visitors, guests, employees or the public, (v) permit us to pursue available remedies or limit the damages that we may sustain, (vi) enforce our websites’ terms and conditions, and (vii) respond to an emergency.
We may also aggregate or anonymize personal information (for example, we may aggregate personal information to calculate the percentage of our users who have a particular telephone area code) or collect demographic data such as date of birth, gender and marital status.
Because Other Information does not personally identify you, such information may be disclosed for any purpose. In some instances, we may combine Other Information with personal information. If we do combine any Other Information with personal information, the combined information will be treated by us as personal information in accordance with this Statement.
The term “sensitive information” refers to information related to your racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership. We do not generally collect sensitive information unless it is volunteered by you. We may use health data provided by you to serve you better and meet your particular needs.
Personal Information From Children
We do not knowingly collect personal information from individuals under 18 years of age. As a parent or legal guardian, please do not to allow your children to submit personal information without your permission.
Mobile and Location-Based Services
To book a reservation from a mobile device or one of our apps, you will be required to enter some personal information. To view or change reservations or to book a reward stay, you will be required to sign in to your HHonors account or you will be required to provide your confirmation number and additional security codes.
We provide mobile apps that can be downloaded to smart phones. These apps have a variety of functionalities that enhance the customer experience. In addition to providing services, our apps may collect personal and Other Information that will be used in accordance with this Statement. For example, our Digital Key functionality within the HHonors App collects information we already have about you, including your HHonors number and user id, and additional information, including use of the key. We provide a link to this Statement to customers prior to their downloading of any of our apps.
Our mobile apps may use your device’s Global Positioning System (GPS) technology to locate a hotel near you and/or to provide you with relevant location-based information. We may also share this information with third parties. We will abide by your device’s settings when accessing any geo-location data. To the extent any geo-location data is combined with personal information, that information will be treated as personal information in accordance with this Statement.
For certain properties, we also make available a “virtual concierge” application, which may be pre-loaded on a Hilton-owned device, or may be downloadable to your web-enabled mobile device. Using these applications, you can order services from the hotel, such as room service or valet parking; access our websites; access third-party websites, including local attractions and social media; and book a reservation. To order services from the hotel, you will be required to enter your name and room number, and you can request order confirmation via SMS messaging. If you request SMS confirmation, you will be required to enter your phone number and carrier. If you book a reservation, you will be required to sign in to your HHonors account or enter your confirmation number and security codes.
Links to Third-Party Websites
Our site and our mobile applications may contain links to third parties’ websites. Please note that we are not responsible for the collection, use, maintenance, sharing, or disclosure of data and information by such third parties.
Other third-party websites include the landing page of the high-speed Internet providers at our hotels, as well as social media sites (such as Facebook and Twitter) on which Hilton or our properties may have accounts or fan pages where you may be able to post information and materials.
Protecting Personal Information
Hilton will take reasonable measures to: (i) protect personal information from unauthorized access, disclosure, alteration or destruction, and (ii) keep personal information accurate and up-to-date as appropriate. We also seek to require our affiliates and service providers with whom we share personal information to exercise reasonable efforts to maintain the confidentiality of personal information about you. For online transactions, we use reasonable technology to protect the personal information that you transmit to us via our site. Unfortunately, however, no security system or system of transmitting data over the Internet can be guaranteed to be entirely secure.
For your own privacy protection, we encourage you not to include sensitive personal information in any emails you send to us. Please do not send credit card numbers or any sensitive personal information to us via email.
We will not contact you by mobile/text messaging or email to ask for your confidential personal information or credit card details. We will only ask for your confidential personal information or credit card details by telephone when you are booking a reservation or promotional package by telephone. We will not contact you to ask for your HHonors account log-in information. If you receive this type of request, you should not respond to it. We also ask that you please notify us at ISC@hilton.com.
Changing and Accessing Your Personal Information
If you are an HHonors member, the information you provided to us at the time of registration may be accessed, reviewed and updated at any time by signing in to your HHonors profile.
To the extent required by applicable law, you may be able to request that we inform you about the personal information we maintain about you and, where appropriate, request that we update, correct and/or suppress personal information about you that we maintain in our active database. We will make all required updates and changes within the time specified by applicable law and, where permitted by law, may charge an appropriate fee to cover the costs of responding to the request. Such requests must be submitted in writing to the following address: Hilton Customer Privacy Department, 7930 Jones Branch Drive, McLean, VA 22102, USA. To protect your confidentiality, we can only respond to such requests to the email address that you have registered or otherwise provided to us. Please remember that if you make such a request, we may not be able to provide you with the same quality and variety of services to which you are accustomed.
In addition, in some circumstances based on applicable law, you may request that we cease sharing personal information about you with our business partners or that Hilton cease using personal information about you on the grounds that such personal information was acquired by unjust means or used in violation of law by sending your written request to Hilton Customer Privacy Department, 7930 Jones Branch Drive, McLean, VA 22102, USA. We will seek to honor those requests consistently with applicable law.
Retaining Personal Information
We retain personal information about you for the period necessary to fulfill the purposes outlined in this Statement, unless a longer retention period is required or permitted by applicable law.
Choices – Marketing Communications
If you have given us your contact information (mail address, fax number, email address or phone number), we may want to inform you about our products and services or invite you to events by email, telephone, mobile/text messaging (including SMS and MMS) or post.
If you are an HHonors member, you may receive additional communications from us, including HHonors statements, third-party news and offers specifically for HHonors program members, and co-branded messages from our business partners. HHonors members of certain levels may also receive post-stay emails from us. You may change the communications you receive from us by logging on to your online account and managing your subscriptions, or by writing to us (and including your email address) at Hilton Customer Privacy Department, 7930 Jones Branch Drive, McLean, VA 22102, USA.
Please note, however, that if you change the communications you receive from us as described above, we will not be able to remove your personal information from the databases of affiliates, franchisees or business partners with whom we have already shared your personal information (i.e., to whom we have already provided your personal information as of the date of your opt-out request).
If you prefer not to receive email marketing materials from us, you may opt-out at any time by using the unsubscribe function in the email you receive from us or by clicking this link: https://secure.hilton.com/en/hhonors/optout/unsubscribe.jhtml?listid=0. Opt-out requests can take up to ten business days to be effective.
Special Notification for California Residents. Individual customers who reside in California and have provided their personal information to the Hilton Worldwide Portfolio of Brands may request information about our disclosures of certain categories of personal information to third parties for their direct marketing purposes. Such requests must be submitted to us at one of the following addresses: CA_Privacy@Hilton.comor Hilton Worldwide, Inc., 7930 Jones Branch Drive, McLean, VA 22102, USA. Within thirty days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted to addresses other than the addresses specified in this paragraph.
We may modify this Statement from time to time. When we make material changes to this Statement we will post a link to the revised Statement on the homepage of our site. You can tell when this Statement was last updated by looking at the link and at the date at the top of the Statement. Any changes to our Statement will become effective upon posting of the revised Statement on the site. Use of the site following such changes constitutes your acceptance of the revised Statement then in effect.
If you have any questions about this Statement or how Hilton processes your personal information, please contact us by email firstname.lastname@example.org or by postal mail to Hilton Customer Privacy Department, 7930 Jones Branch Drive, McLean, VA 22102, USA.
Hilton Worldwide Privacy Statement Revisions
As stated above, we may modify this Statement from time to time. To help you track the most significant changes, we will include a history of changes, below, so that you are aware of modifications to our Statement.
Last Update: May 2015
- Updated to Address new Digital Key functionality in the HHonors App
November 2013 Changes:
- Updated to change the word “Policy” to “Statement.”
- Updated to create separate Cookies Statement to provide more transparency on how we use first- and third-party cookies.
- Updated to provide more clarity around our eFolio program.
- Updated to link out to our Applicant Privacy Notice.
- Updated to provide additional notice regarding information that we may collect from third parties used to append to customer data.
- Updated to provide further clarity regarding the sharing of personal information, particularly telephone numbers, between and among our affiliates, for purposes of telemarketing.
- Updated information on the use of audio and video recordings (including audio recording and monitoring of customer service calls and audio and video recordings to protect our employees).
- Updated to provide additional information about our apps and location-based services.
- Updated to address how we will use your personal information if you visit one or more of our properties as part of a group or event.
- Updated to address sharing of information with co-sponsors of promotions, sweepstakes, and similar events.
- Updated to provide more current information about how to opt-out of marketing email communications.