Dorchester Collection

California Consumer Privacy Policy

Last updated and effective: February 2024

Introduction

This CCPA Privacy Policy is provided for California residents pursuant to the California Consumer Privacy Act as amended by the California Privacy Rights Act (“CCPA”). If you are a California resident (“you” or “your”), this CCPA Privacy Policy supplements our general Privacy Policy and provides you with additional information about Dorchester Collection and its hotels’ (“the Hotel,” “we,” “us,” or “our”) practices regarding your Personal Information, along with your rights regarding your Personal Information. This CCPA Privacy Policy, along with our general Privacy Policy, tells you how Dorchester Collection and its hotels use your Personal Information when you visit our website, when we welcome you as our guest, when you apply for employment with us, or when you otherwise interact with us, whether online or offline. 

 

If you are not a California resident, please see our general Privacy Policy which you can find here.

 

It is important that you read this CCPA Privacy Policy together with our general Privacy Policy and any other privacy notices we may show you from time to time, so that you are fully aware of how and why we are using your Personal Information. If you do not understand this privacy policy or you have any questions, please contact us before using our products, services, features, activities, programs, or offerings.

Types of Personal Information we collect

“Personal Information” is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person.

 

We collect a variety of Personal Information about our guests, customers and visitors to our website. Our products, services, features, activities, programs, and offerings are not intended for children or those under the age of 16, so we do not knowingly collect Personal Information relating to children or those under the age of 16. If you think we have received personal data from children or those under the age of 16, please contact us immediately.

 

The Personal Information that the Hotel has collected in the preceding 12 months fall into the following categories:

 

  • Identifiers includes title, gender, first name, maiden name, last name, social security number, driver’s license number or state identification card number, passport number, username or similar identifier and an encrypted version of your login/password. If you interact with us through social media, this may include your social media username.
  • Protected Characteristics includes age, colour, disability, gender identity/expression, marital status, medical condition, national origin, race, religion, sex/gender.
  • Commercial Information includes credit card number, debit card number, bank account number, details about payments to and from you, details of products and services you have purchased from us, and your purchasing preferences.
  • Internet or other electronic network information includes your login data and information we collect about you from cookies.
  • Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information includes photos and videos.
  • Professional or Employment Related Information includes your employer and job title or position.
  • Inferences drawn from any of the Personal Information listed here to create a profile or summary about you. Such as your online profiled data, including your interests, preferences, feedback and survey responses, as well as any data which we have added (for example, using analytics and profiling), and your preferences in receiving direct marketing from us and our third parties and your communication preferences.
  • Sensitive Personal Information includes personal information regarding your medical information, in particular, allergies and disabilities.

 

Job applicants

 

If you apply for employment with us, we may collect your name, gender, date of birth, race/ethnicity, employment status and history, education history, certifications, and other employment-related information in addition to the information listed above.

How we collect your personal information

The Hotel acquires this information from the following categories of sources:

  • You directly, including when you contact us;
  • Group or corporate bookings;
  • Publicly available sources;
  • Social media, where privacy settings are set to public;
  • Cookies;
  • Third party booking services;
  • Technology partners;
  • Payment and fraud prevention services;
  • Analytics providers;
  • Data partners;
  • Feedback and review partners;
  • Third parties to whom you have given permission to share your data with us; and
  • Third parties who are permitted by law to share your personal data with us.

 

For an explanation of the main ways we collect this information, see the section on “How we collect data” on our general Privacy Policy which you can find here.

How and why we use your Personal Information

We primarily use your Personal Information to operate, manage, and maintain our Hotel’s business, including to provide our products, services, features, activities, programs, and offerings.

 

Click here to see a table explaining the types of Personal Information we collect and the business or commercial purpose for collecting it. 

 

If you apply for employment with us, we will use your Personal Information to determine your fitness for the position applied for, to make any relevant adjustments during the recruitment process and for equal opportunities monitoring, as well as the purposes listed in the table above.

 

Typically, we retain Personal Information for the period necessary to fulfill the purposes outlined in our Privacy Policies, unless a longer retention period is required or permitted by law. In many situations, we must retain some or all of your Personal Information to comply with our legal obligations; resolve disputes; enforce our agreements; protect against fraudulent, deceptive, or illegal activity; or for other legitimate business purposes, such as for auditing, accounting, or tax purposes.

What Personal Information have we shared to third parties

We do not sell Personal Information and we do not share Personal Information with third parties for cross-context behavioural advertising purposes.

 

We share your Personal Information with third parties, including within the Dorchester Collection group and affiliates, for our operational business purposes and the purposes listed in our general Privacy Policy which you can find here: https://www.dorchestercollection.com/privacy-policy. Third parties include our suppliers and service providers (for example, booking and reservation systems, customer relationship management systems, payment processors, fraud prevention providers, and fulfilment partners for the gift shop), technology and media providers, professional advisors (for example, bankers, lawyers, accountants and insurers), government, regulators, and law enforcement.

 

We also share Personal Information with third parties connected to advertising, retargeting, and analytics, but never for cross-context behavioural advertising purposes. For example, we do not share Personal Information with third parties for the purpose of facilitating targeted advertising on other websites based on your visit to this website.  

 

In the preceding 12 months, we shared the following Personal Information with third parties for our operational business purposes:

 

Category of Personal Information Disclosed Categories of Recipients
Identifiers
  • Suppliers and Service Providers
  • Dorchester Collection group and affiliates
  • Auditors and professional advisors like bankers, lawyers, accountants, and insurers
  • Government regulators and law enforcement
  • Third Parties connected to advertising, retargeting, and analytics
Protected Characteristics
  • Suppliers and Service Providers
  • Dorchester Collection group and affiliates
  • Auditors and professional advisors like bankers, lawyers, accountants, and insurers
  • Government regulators and law enforcement
  • Third Parties connected to advertising, retargeting, and analytics
Commercial Information
  • Suppliers and Service Providers
  • Dorchester Collection group and affiliates
  • Auditors and professional advisors like bankers, lawyers, accountants, and insurers
  • Government regulators and law enforcement
  • Third Parties connected to advertising, retargeting, and analytics
Internet or Other Electronic Activity Information
  • Suppliers and Service Providers
  • Dorchester Collection group and affiliates
  • Third Parties connected to advertising, retargeting, and analytics
Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information
  • Suppliers and Service Providers
  • Dorchester Collection group and affiliates
  • Auditors and professional advisors like bankers, lawyers, accountants, and insurers
  • Government regulators and law enforcement
Professional or Employment related information
  • Suppliers and Service Providers
  • Dorchester Collection group and affiliates
  • Auditors and professional advisors like bankers, lawyers, accountants, and insurers
  • Government regulators and law enforcement
  • Third Parties connected to advertising, retargeting, and analytics
Inferences drawn from any of the Personal Information listed here to create a profile or summary about you
  • Suppliers and Service Providers
  • Dorchester Collection group and affiliates
  • Third Parties connected to advertising, retargeting, and analytics
Sensitive Personal Information
  • Suppliers and Service Providers
  • Dorchester Collection group and affiliates

Your rights under the CCPA

If you are a California resident, you have the following rights:

 

  • Right to Know what Personal Information we collected, disclosed, or sold.
  • Right to Request that we disclose what Personal Information we collect, use, disclose, and sells, including:
    • The categories of Personal Information that we collected of you,
    • The categories of sources from which the Personal Information is collected,
    • The business or commercial purpose for collecting Personal Information,
    • The categories of third parties with whom we share Personal Information,
    • The specific pieces of Personal Information we have collected about you.
  • Right to Request Deletion of any Personal Information that we collected about you.
  • Right to Request Correction of any inaccurate Personal Information that we have about you.
  • Right to Limit the Use or Disclosure of Sensitive Personal Information that we have collected.
  • Right to be Free From Unlawful Discrimination because you exercised any of your privacy rights under the CCPA.


To make a request for the disclosures or deletion described above, please contact us via this form or call +1 (833) 345-0754. An authorized agent may also complete the foregoing forms or call the toll-free number on your behalf. We will respond to your request consistent with applicable law. This includes matching identifying information provided by you to your Personal Information that we maintain. We will ask you for basic information such as whether you’re a California resident, the nature of your request, your first and last name, email, and details about your purchasing history to verify your identity. If you are making a request to know specific categories of Personal Information we have collected about you, we will ask you to sign a declaration under penalty and perjury that you are the consumer to whom the request pertains. You will not be charged a fee for the verification of your request to know or delete. Once you have submitted your request, we will respond within the time frame permitted by the applicable law. We may charge a reasonable fee for multiple requests in the same 12-month period, as permitted by law.


We do not share personal information with third parties for their own direct marketing purposes without your consent. California residents under 18 years old, in certain circumstances, may request and obtain removal of personal information or content that you have posted on our Services. Please be mindful that this would not ensure complete removal of the content posted by you on our Services. To make any request pursuant to California privacy law, please contact us.


To designate an authorized agent you must (1) verify your own identity directly with us; and (2) provide the authorized agent with written documentation of their authority to act on your behalf, such as: (a) a power of attorney; or (b) sufficient evidence to show that you have provided the authorized agent signed permission to act on your behalf and directly confirmed with us that you provided the authorized agent permission to submit the request on your behalf. Please note, we may deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf.

Notice of Financial Incentives

The Dorchester Collection and its Hotels offer loyalty programs and memberships, that vary depending on the property. Because our loyalty program involves the collection of Personal Information, it might be interpreted as a “financial incentive” program under California law. The benefits of becoming a member of a loyalty program may include:

 

  • Signing privileges to a monthly account;
  • Complimentary valet parking for dining in Hotel restaurants;
  • Accommodation upgrade and complimentary amenities for you and referred guests;
  • Guaranteed reservations with preferential seating in restaurants;
  • A 20% discount on Hotel logo items; and
  • Complimentary use of boardrooms, based upon availability.

 

The benefits of signing up for a membership include:

 

  • Access to facilities such as fitness centres and pools;
  • Complimentary daytime valet parking;
  • Massage services;
  • Discounts on retail products and spa treatments;
  • Discounts at Hotel restaurants;
  • Discounts on Hotel guestroom reservations;
  • Discounts at the Hotel boutiques;
  • Discounts at salons located at the Hotels;
  • House account charging privileges;
  • Invitation plus one guest to exclusive spa and wellness events; and
  • Preferred reservations at promotional events.

 

The categories of Personal Information that are implicated by loyalty programs and memberships include:

 

  • Identifiers such as name, signature, postal address, email address, and telephone number
  • Protected Characteristics such as gender and age
  • Commercial Information such as credit card number, debit card number, and bank account number. 
  • Professional or Employment related information such as employer and job title or position.

 

To inquire on the loyalty programs or membership provided at each property, please contact [email protected] and [email protected].

 

If you choose to participate in any of the financial incentives offered by the Hotel, you have the right to withdraw from the financial incentive at any time. You may submit a request to withdraw from the financial incentive at any time by completing this form or by calling +1 (833) 345-0754.

 

The value of your Personal Information to us is related to the value of the free or discounted products or services, or other benefits that you obtain or that are provided as part of the loyalty program, less the expense related to offering those products, services, and benefits to loyalty program participants.

 

If you have any questions about this California Consumer Privacy Policy, please do not hesitate to email us at [email protected] or send a letter addressed to: Privacy Manager, The Beverly Hills Hotel, 9641 Sunset Boulevard, Beverly Hills, CA, 90210 or Privacy Manager, Hotel Bel-Air, 701 Stone Canyon Road Los Angeles, CA, 90077.