Last Updated: July 2023
The Leading Hotels of the World, Ltd. (“LHW,” “we,” or “us”) is committed to protecting the information that you share with us online, and explaining how we collect, process, and share that information. We provide you with the notice below in English only to avoid any misinterpretations caused by a language translation. If necessary, please seek the proper advice, or avoid use of this website.
| Use | We use Personal Information for a number of reasons, e.g. to provide you with services such as maintaining your account or processing reservations, to build features that will make the services available on the Site easier to use, to contact you about these services, and to send advertisements, marketing material or other offers that we think might be of interest to you. |
| Sharing | We share your Personal Information with our member hotels, affiliated companies, external service providers, third party vendors, agents, and others as necessary to perform transactions with you and as expedient as part of our business. |
| Categories of Collected Data | We collect Personal Information about you that you provide to us or that we obtain while you are using the Site. |
| Categories of Disclosed Data | We may disclose any of the categories of Personal Information about you that we collect for the purposes described in this Privacy Policy. |
| Cross-Border Data Transfers | Our Site is operated in the United States. If you are located outside the US, your Personal Information will be transferred to the US, a jurisdiction that may not provide an equivalent level of protection as your home jurisdiction. Cross-border transfer is, therefore, necessary for the conclusion or performance of a transaction that you are requesting, and for the establishment, exercise, and defense of legal claims. For transfers originating in the European Economic Area ("EEA") or United Kingdom, LHW has implemented other appropriate cross-border transfer solutions, in accordance with Article 46 or Article 49 of the European Union General Data Protection Regulation and the United Kingdom General Data Protection Regulation, respectively, to provide adequate protection for transfers of certain personal information from the EEA or the United Kingdom to the U.S. For transfers originating in Switzerland, LHW transfers data to the U.S. in compliance with Article 17 of Switzerland’s Federal Act on Data Protection, as further described below. |
| Access and Data Subject Rights | LHW understands that you may want to change, access, or delete your Personal Information. You may do so by accessing your profile or by contacting us here. |
| Protection | We employ reasonable and current technical, administrative, and physical safeguards that are designed to prevent unauthorized access, maintain data accuracy, and ensure correct use of Personal Information. |
| Retention | We will maintain Personal Information in accordance with applicable law and while it is needed and will delete it after that, though we may retain it in de-identified form. |
| Children | Persons under the age of 16 are not eligible to use any services on our Site. |
| Cookies | Our Site uses cookies and other similar technologies. To opt-out of advertising and certain other cookies, please click here. |
| Changes | We will provide notice of any material changes to this Privacy Policy by posting a prominent notice on our Site and/or emailing you. |
| Contact Us | Should you have any questions, concerns or comments, you can email us by clicking here. You also can contact us at The Leading Hotels of the World, Ltd., 485 Lexington Avenue, Suite 401, New York, NY 10017, USA. |
This Privacy Policy applies to information collected on our websites, mobile applications, cloud-based services, or controlled widgets embedded in communication platforms with a link to this Privacy Policy (collectively, the “Site”). It covers how we collect, use, share, and otherwise process Personal Information as of the date that this Privacy Policy is posted. It does not apply to any other information collected by LHW through any other means. By “Personal Information,” we mean information that identifies or can identify you personally.
The Site contains links to third-party websites, including websites of our independently-owned member hotels. We do not own, operate or control the websites of those third parties, or of LHW member hotels, reservation agents, or travel sales associates. Accordingly, this Privacy Policy does not apply to any websites maintained or operated by unaffiliated third parties. When you click on those links, you will go to a third party website where you will be subject to that website’s privacy policy, which we encourage you to read. We are not responsible for the privacy practices of those other websites, including those of our independent member hotels, and we expressly disclaim any liability for their actions, including actions relating to the use and disclosure of Personal Information.
We collect your Personal Information on the Site to enhance the services we offer you, maintain and improve the Site, protect the security of you and our Site, comply with legal obligations, and inform you about other services and products that may be available through us, our affiliated companies, or through our marketing alliances. We collect Personal Information about you when you interact with or utilize services offered on this Site, such as:
Personal Information includes:
For Leaders Club members, we also collect your gender, language preference, information about your spend on rooms at LHW member hotels and your date of birth if you provide it to us.
Even if you do not provide us with any Personal Information, we collect certain non-personal information about how you use our Site. This information cannot identify you and is used for statistical purposes only.
We only process and share your Personal Information, including sharing with service providers or other external entities, to the extent reasonably necessary to fulfill your requests and meet our legitimate business and legal objectives. When we disclose Personal Information to external entities to perform services for us, we establish by contract that they may access your Personal Information only for the purposes of performing those services. We may also use what we know about you to offer you other products and services. We may combine your online information with information collected from offline or online sources, or information we already have. We may also use and disclose certain Personal Information to our affiliated companies and others for any purpose allowed by law.
We generally process and may disclose your Personal Information to others to:
LHW uses sensitive Personal Information solely for purposes that you would anticipate in providing us the information, for example, if you reserve an accessible room.
The following chart provides information about the types of Personal Information that we collect, the sources of the information, the purposes for which we use the information, whether the information has been disclosed for a business purpose, and the categories of third parties with whom we have shared this information in the last 12 months.
| Type of Information | Categories of Sources | Business or commercial purposes for collection | Discolosed for Business Purpose | Third parties to whom Disclosed for Business Purpose |
|---|---|---|---|---|
| Identifiers such as a real name, alias, postal address, prefix, unique personal identifier, email address, account name, telephone and birthday. | Direct contact with users including Leaders Club members, through the Site, phone, email, and social media; user interaction with the Site and the mobile app. | To provide customers with products, administer Leaders Club accounts and provide customers with membership benefits, and services and for internal purposes. | Yes | Service providers; member hotels; affiliated companies; marketing partners. |
| Hotel experience preferences that customers can choose to share, including smoking preferences, pillow type, bed preferences, floor preferences, preferred newspaper, beverage and snack preferences, and special interests. | Direct contact with users including Leaders Club members, through the Site, mobile app and phone. | As described above, e.g., to provide customers with products, administer Leaders Club accounts and provide customers with membership benefits, and services and for internal purposes. | Yes | Member hotels and our third party reservation agents |
| Financial information such as credit card number or debit card number. | Direct contact with users, including Leaders Club members, through the Site, mobile app and phone. | As described above, e.g., to provide customers with products, administer Leaders Club accounts and provide customers with membership benefits, complete transactions and for internal purposes. | Yes | Service providers, member hotels and payment processors. |
| Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | Direct contact with users, including Leaders Club members, through the Site, mobile app, phone, email, social media; user interaction with the Site; cookies and other tracking technologies. | As described elsewhere, e.g., for internal use, to administer Leaders Club accounts and provide customers with membership benefits, and marketing purposes. | Yes | Service providers; member hotels; affiliated companies; marketing partners |
| Internet or other electronic network activity information, including, but not limited to, browsing history, search history, information regarding a user’s interaction with the Site and mobile app. | User interaction with the Site and mobile app; cookies and other tracking technologies | As described above, e.g. to operate the Site and for other internal purposes; and as described elsewhere herein regarding cookies, e.g. for internal purposes and for marketing purposes. | Yes | Service providers; marketing partners |
| Inferences drawn from any Personal Information collected to create a profile about a consumer reflecting the consumer’s interests, frequency of travel and travel preferences. | Direct contact with Leaders Club members, through the Site, phone, email; user interaction with the Site; cookies and other tracking technologies. | As described above, in order to facilitate targeted marketing, to administer Leaders Club accounts and provide customers with membership benefits, as well as for internal reporting, service provision and analytics purposes. | No | N/A |
| Professional or employment information and LHW employee information, including employee identification number, identifiers and address details, contact information, employment details, job location, financial or payroll related information, other potentially sensitive Personal Information including National or State Identification Numbers for various employment-related purposes or background checks, and dependent information for the administration of certain employee benefits or programs. | Direct contact with LHW employees and prospective hires; direct contact with users through the Site; phone; and email. | To conduct background checks, for other purposes in the ordinary course of employment (e.g., to facilitate onboarding processes, manage compensation, provide benefits, review performance), and to process applications for potential employment. | Yes | Service providers; third parties for operational purposes, including where permitted or with consent, with third parties such as future employers, or pursuant to legal request. |
| Sensitive Personal Information, including gender, credit card information, disability, and precise geolocation data. | Direct contact with users, including Leaders Club members, and LHW employees. | To administer Leaders Club accounts and to provide customers with membership benefits, internal reporting and analytics purposes, and for other purposes in the ordinary course of business. | Yes | Service providers; member hotels; affiliated companies; third parties for operational purposes. |
The following chart provides information about the types of Personal Information that we disclose, the purposes for which we disclose the information where a disclosure is for the purpose of targeted or cross-context advertising (under California law, this is called “Sharing”), and the categories of third parties to whom we disclosed the information for business purposes in the last twelve (12) months. Note that LHW does not sell or share the Personal Information [of minors under 16 years of age] and has no actual knowledge of any such sales or disclosures.
| Type of Information | Disclosed for Targeted Advertising? | Third parties to whom Disclosed for Targeted Advertising | Business or commercial purposes for Disclosing for Targeted Advertising |
|---|---|---|---|
| Identifiers such as a real name, alias, postal address, prefix, unique personal identifier, email address, account name, telephone, and birthday. | Yes | Service providers, member hotels; affiliated companies; marketing partners; third parties for operational purposes | As described above, e.g. to provide customers with products and services and for internal purposes. |
| Professional or employment-related information. | Yes | Service providers. | To process applications for potential employment and for internal employment and benefit purposes. |
| Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | Yes | Service providers; member hotels; affiliated companies; marketing partners. | As described elsewhere, e.g. for internal and marketing purposes. |
| Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with our website and mobile app. | Yes | Service providers; marketing partners | As described above regarding cookies, e.g. for internal purposes and for marketing purposes. |
| Geolocation data. | Yes | Service providers; marketing partners | As described elsewhere herein regarding cookies, e.g. for internal, marketing, and other operational and business purposes. |
| Inferences drawn from any Personal Information collected to create a profile about a consumer reflecting the consumer’s interests, travel preferences, and frequency of travel. | Yes | Service providers; member hotels; affiliated companies; marketing; third parties for operational purposes. | As described above, in order to facilitate more targeted marketing, as well as for internal reporting and analytics purposes. |
Our Site is operated in the United States. If you are located outside the US, your Personal Information will be transferred to the US, a jurisdiction that may not provide an equivalent level of protection as your home jurisdiction. Cross-border transfer is, therefore, necessary for the conclusion or performance of a transaction that you are requesting, and for the establishment, exercise, and defense of legal claims. For transfers originating in the EEA or the United Kingdom, LHW has implemented other appropriate cross-border transfer solutions, in accordance with Article 46 or Article 49 of the European Union General Data Protection Regulation and the United Kingdom General Data Protection Regulation, respectively to provide adequate protection for transfers of certain personal information from the EEA or the United Kingdom to the U.S. For transfers originating in Switzerland, LHW transfers data to the U.S. only when you enroll in our Leader’s Club, which transfer is permitted pursuant to Article 17 of the Federal Act on Data Protection because such transfers are necessary to fulfill the Leader’s Club agreement between you and LHW, and/or because you have consented to such transfer as part of such enrollment.
Certain jurisdictions, including those in Europe, require the identification of the legal grounds for the collection, use, sharing, and other processing of Personal Information. LHW relies on the following legal grounds for its collection, use, sharing, and other processing of Personal Information as described in this Privacy Policy:
Providing us with Personal Information is voluntary, but your refusal to provide Personal Information for the above-mentioned purposes may affect our ability to fulfill our contractual obligations or to provide you with The Leaders Club benefits or other LHW Site benefits, services, information, and or material requested by you. Even so, unless otherwise specified, not providing your Personal Information will not result in any direct legal consequences for you.
You have the following choices regarding our use and disclosure of your Personal Information:
You are not required to provide all Personal Information identified in this Privacy Policy to use our Site, but certain aspects of our Site will not be available to you. However, you can use our services without consenting to non-essential cookies or direct marketing emails; the only consequence is that we will communicate less to you regarding our member hotels, The Leaders Club, and our services, we may not be able to provide the support you seek, and you may miss out on attractive promotions and news about our member hotels, The Leaders Club and our services.
Additionally, some data protection regulations confer certain data protection rights on individuals. LHW provides these rights to you regardless of your location:
EXERCISING YOUR RIGHTS
If you wish to exercise any of the rights, you may contact us or visit https://www.lhw.com/customer-care. You may also be able to exercise certain rights, such as updating and correcting your Personal Information, through your account. If you make a request to exercise one of your privacy rights via e-mail, please include "Privacy Rights Request" in the subject line of the email. Your exercise of these rights will have no adverse effect on the price and quality of our services. When you make a request, you can expect the following:
"SHINE THE LIGHT" LAW
Under California Civil Code Section 1798.83, California residents with whom we have an established business relationship are entitled to request and receive, free of charge, once per calendar year, information about the Personal Information we shared, if any, with other businesses for their own direct marketing uses during the prior year.
You can make such a request by contacting us. Please include “Shine the Light Inquiry” in your email subject line if you contact us by email.
We maintain reasonable technical, electronic, and organizational security procedures to maintain the security of Personal Information, and safeguard Personal Information against unauthorized or unlawful processing and/or against accidental or unlawful loss, alteration, disclosure or access. Our security procedures include contractual terms with any contractors, agents or data processors that require such entities to protect the security and confidentiality of Personal Information in accordance with our standards. While we strive to protect your Personal Information, we cannot ensure the security of the information you transmit. It is your responsibility to safeguard any email or password that you have created or used in connection with The Leaders Club and any LHW Site and to notify us if you ever suspect that the security and confidentiality of such email or password has been compromised in any way. You are solely responsible for any use of your The Leaders Club account via your email and password.
We will maintain Personal Information for as long as we are required to do so by applicable law(s), or for as long as necessary for the purpose(s) described above for which it is processed. We will delete Personal Information when it is no longer needed. However, we may maintain and use information in a de-identified form and will not attempt to re-identify the information, except that we may attempt to re-identify the information solely for the purpose of determining whether our de-identification process satisfies the requirements of this policy and applicable law.
LHW does not knowingly collect Personal Information from children under the age of 16, and users under the age of 16 should not submit any Personal Information to LHW. If LHW has actual knowledge that Personal Information about a child under 16 years old has been collected, then LHW will take the appropriate steps to delete this Personal Information.
Information Collected Through Technology. Information is also obtained in other ways through technology. Some of this information may be linked to you personally. In accordance with applicable law, LHW uses and allows third parties to use essential and non-essential cookies, online tracking tools, web beacons, and similar technologies (collectively, “cookies”) on our Sites. We process this information to help our Sites function correctly and better understand the needs of our customers.
Device Information. Depending on the permissions you’ve granted and other factors, we may receive information about your location and your mobile device when you download or use apps created by our Sites, including a unique identifier for your device. Examples of the device information we collect include:
Cookies on our Site generally fall into the following categories:
Use of Cookies. We advertise in a number of ways, including online through managed social media presences, and on other unaffiliated sites and mobile applications. To understand how our advertising campaigns are performing, we may collect certain information via cookies on our Sites through our advertising service providers. The information we collect includes IP addresses, the number of page visits, timestamps, session duration, pages viewed via our Sites, search engine referrals, browsing activities and actions taken over time and across other websites following your visit to our Sites or applications, and responses to advertisements and promotions on the websites and applications where we advertise.
We also use certain information to identify new visitors to our Sites, recognize returning visitors, advertise on other websites and mobile applications not affiliated with us, analyze the effectiveness of our advertisements, better understand our audience, customers, or other visitors of our Sites, and determine whether you might be interested in new products or services.
Controlling Our Tracking Tools.
There are several ways that you may manage and change your cookie settings. If, however, you choose to reject all optional cookies, you may experience some inconvenience when using and limitations in the functionality we can provide (e.g., we will not be able to provide you with searches that you have asked us to save or to recognize your computer, which will result in the need for you to log in each time you visit the Sites). Please note that you cannot opt out of Strictly Necessary Cookies as they are required for the operation of our Sites.
Browser Settings: Your browser may give you the ability to control cookies. How you do so, however, depends on your browser and the type of cookie. Some browsers have a “Do Not Track” feature that lets you tell websites that you do not want to have your online activities tracked. These browser features are still not uniform, so we are not currently set up to respond to those signals.
Tracking Preferences/Cookie Banner: You will be able to manage to which cookies (other than those that are categorized as strictly necessary) you would like to opt in. Your cookie preferences can be updated at any time on our Cookie Preferences page.
Controlling Online Interest-Based Ads. We sometimes work with online advertising vendors to provide you with relevant and useful ads. This may include ads served on or through our Sites. This may also include ads served on other companies’ websites. These ads may be based on information collected by us or third parties. For example, your postal code may be used to target an ad for people in your area. These ads may also be based on your activities on our Sites or on third-party websites.
For more information about our ad service provider and its cookies, including information about how to opt out of these technologies, you may visit https://optout.aboutads.info In addition, users may prevent Google’s collection of data generated by your use of the Site (including your IP address) by downloading and installing a Browser Plugin available at https://tools.google.com/dlpage/gaoptout?hl=en.
We may change this policy from time to time. If we make any material change in how we collect, use, disclose, or otherwise process Personal Information, we will prominently post notice of the change on our site for at least thirty (30) days before putting the change into effect. Where required to do so by law, we may seek your prior consent to any material changes we make to this Privacy Policy. Otherwise, your continued use of our site after we make changes to this policy is deemed acceptance of those changes. If any proposed change is unacceptable to you, you may request that we remove your Personal Information (and/or that of other individuals for whom you made your travel reservations) from our records.
If you have any questions or comments regarding this Privacy Policy or our privacy practices in general, please contact us as detailed below. You may also have a right to lodge a complaint with a supervisory authority.
Email: privacy@lhw.com
Mailing Address:
The Leading Hotels of the World, Ltd.
485 Lexington Avenue, Suite 401
New York, NY 10017
USA
Attn: General Counsel
France
The Leading Hotels of the World (France) SARL
Address: 29/31, rue de Courcelles - 75008 Paris
Tel: (33-1) 53-67-10-10
E-mail: privacy@lhw.com
Italy
The Leading Hotels of the World Ltd. (Milan branch office)
Address: Via Manuzio, 7, 20124, Milan, Italy
Tel: (39-02) 669-86131
E-mail: privacy@lhw.com
United Kingdom
The Leading Hotels of the World, Limited
Address: 16 Berkeley Street, London WIJ 8DZ
Tel: (44-12) 3355-4900
E-mail: privacy@lhw.com