Privacy Policy - The Listel Hotel Whistler

Overview
Listel Hospitality Group values you as our guest and recognizes that privacy is important to you. We want you to be familiar with how we collect, use and disclose data.

This Privacy Policy applies to Listel Canada Ltd and to all the businesses of Listel Canada Ltd (collectively “Listel Hospitality Group”) including:

Forage
Timber
The Listel Hotel Whistler
The Listel Hotel Vancouver
Forage Catering
Bearfoot Bistro
Cheakamus Centre

We are very much aware of your concerns about the privacy of your personal information, and we have no desire or intent to infringe on your privacy.

This Privacy Policy describes the privacy practices of the Listel Hospitality Group for data that we collect:

through websites operated by us from which you are accessing this Privacy Policy, including websites owned or controlled by the Listel Hospitality Group (collectively, the “Websites”)
through the software applications made available by us for use on or through computers and mobile devices (the “Apps”)
through our social media pages that we control from which you are accessing this Privacy Policy (collectively, our “Social Media Pages”)
through HTML-formatted email messages that we send you that link to this Privacy Policy and through your communications with us
when you visit or stay as a guest at one of our properties, or through other offline interactions

Collectively, we refer to the Websites, the Apps and our Social Media Pages, as the “Online Services” and, together with offline channels, the “Services.” By using the Services, you agree to the terms and conditions of this Privacy Policy.

This policy outlines the following:

the type of personal information we collect and receive;
the circumstances in which we collect or receive personal information;
the policies and procedures we have established outlining its use and storage, and for sharing certain types of personal information in certain limited circumstances; and
the procedures and communication means you should follow if you have any questions or requests in respect of your personal information or our policies and procedures.

Collection of personal data
In this Policy, “Personal Data” are data that identify you as an individual or relate to an identifiable individual.

At touchpoints throughout your guest journey, we collect Personal Data in accordance with law, such as:

Name
Gender
Postal address
Telephone number
Email address
Credit and debit card number or other payment data
Financial information in limited circumstances
Language preference
Date and place of birth
Nationality, passport, visa or other government-issued identification data
Important dates, such as birthdays, anniversaries and special occasions
Membership or loyalty program data (including co-branded payment cards, travel partner program affiliations)
Employer details
Travel itinerary, tour group or activity data
Prior guest stays or interactions, goods and services purchased, special service and amenity requests
Geolocation information
Social media account ID, profile photo and other data publicly available, or data made available by linking your social media and loyalty accounts

In more limited circumstances, we also may collect:

Data about family members and companions, such as names of children
Images and video and audio data via security cameras located in public areas, such as hallways and lobbies, in our properties.
Guest preferences and personalized data (“Personal Preferences”), such as your interests, activities, hobbies, food and beverage choices, services and amenities of which you advise us or which we learn about during your visit

If you submit any Personal Data about other people to us or our Service Providers (e.g., if you make a reservation for another individual), you represent that you have the authority to do so and you permit us to use the data in accordance with this Privacy Policy.

The Privacy Policy does not apply to information regarding Listel Hospitality Group’s corporate customers or 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 or marketing partners.

HOW WE COLLECT PERSONAL DATA

Online Services.
We collect Personal Data when you make a reservation, purchase goods and services from our Websites, communicate with us, or otherwise connect with us or post to social media pages, or sign up for a newsletter or participate in a survey, contest or promotional offer.
Property Visits and Offline Interactions.
We collect Personal Data when you visit our properties or use on-property services and outlets, such as restaurants, concierge services, health clubs, child care services.

We collect Personal Data when you attend promotional events that we host or in which we participate, or when you provide your Personal Data to facilitate an event.

We also collect Personal Data when you make a reservation over the phone, communicate with us by email, fax or via online chat services or contact customer service. These communications may be recorded for purposes of quality assurance and training.
Strategic Business Partners.
We collect Personal Data from companies with whom we partner to provide you with goods, services or offers based upon your experiences at our properties or that we believe will be of interest to you (“Strategic Business Partners”). Examples of Strategic Business Partners include travel and tour partners, rental car providers and travel booking platforms. Strategic Business Partners are independent from the Listel Hospitality Group.
Other Sources.
We collect Personal Data from other sources, such as public databases, joint marketing partners and other third parties.
Internet-Connected Devices.
We collect Personal Data from internet-connected devices available in our properties.

COLLECTION OF OTHER DATA
“Other Data” are data that generally do not reveal your specific identity or do not directly relate to an individual. To the extent Other Data reveal your specific identity or relate to an individual, we will treat Other Data as Personal Data. Other Data include:

Browser and device data
Data collected through cookies, pixel tags and other technologies
Demographic data and other data provided by you
Aggregated data

HOW WE COLLECT OTHER DATA
We collect Other Data in a variety of ways:

Your browser or device.
We collect certain data through your browser or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, internet browser type and version and the name and version of the Online Services (such as the Apps) you are using. We use this data to ensure that the Online Services function properly.
Cookies.
We collect certain data from cookies, which are pieces of data stored directly on the computer or mobile device that you are using. Cookies allow us to collect data such as browser type, time spent on the Online Services, pages visited, referring URL, language preferences, and other aggregated traffic data. We use the data for security purposes, to facilitate navigation, to display data more effectively, to collect statistical data, to personalize your experience while using the Online Services and to recognize your computer to assist your use of the Online Services. We also gather statistical data about use of the Online Services to continually improve design and functionality, understand how they are used and assist us with resolving questions.

Cookies further allow us to select which advertisements or offers are most likely to appeal to you and display them while you are using the Online Services or to send marketing emails. We also use cookies to track responses to online advertisements and marketing emails

If you do not want data collected with cookies, you can learn more about controlling cookies at http://www.allaboutcookies.org/manage-cookes/index.htm.

You can choose whether to accept cookies by changing the settings on your browser or by managing your tracking preferences by clicking on “Tracking Preferences” located at the bottom of our home page. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Online Services. For example, we will not be able to recognize your computer, and you will need to log in every time you visit. You also will not receive advertising or other offers from us that are relevant to your interests and needs. At this time, we do not respond to browser “Do-Not-Track” signals
Pixel Tags and other similar technologies.
We collect data from pixel tags (also known as web beacons and clear GIFs), which are used with some Online Services to, among other things, track the actions of users of the Online Services (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Online Services.
Analytics.
We collect data through Google Analytics which use cookies and technologies to collect and analyze data about use of the Services. These services collect data regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/ and opt out by downloading the Google Analytics opt out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
Aggregated Data.
We may aggregate data that we collected and this aggregated data will not personally identify you or any other user.

USE OF PERSONAL DATA AND OTHER DATA
We use Personal Data and Other Data to provide you with Services, to develop new offerings and to protect the Listel Hospitality Group and our guests as detailed below. In some instances, we will request that you provide Personal Data or Other Data to us directly. If you do not provide the data that we request, or prohibit us from collecting such data, we may not be able to provide the requested Services.

We use Personal Data and Other Data for our legitimate business interests, including the following:

Provide the Services you request.
We use Personal Data and Other Data to provide Services you request, including:
- To facilitate reservations, payment, send administrative information, confirmations or pre-arrival messages, to assist you with meetings and events and to provide you with other information about the area and the property at which you are scheduled to visit
- To complete your reservation and stay, for example, to process your payment, ensure that your room is available and provide you with related customer service
- To support our electronic receipt program. When you provide an email address in making a reservation, we use that email address to send you a copy of your bill. If you make a reservation for another person using your email address, that person’s bill will be emailed to you, as well. You can opt out of receiving your bill via email and instead receive a paper copy by contacting the front desk
We will use Personal Data and Other Data to manage our contractual relationship with you, because we have a legitimate interest to do so and/or to comply with a legal obligation.
Personalize the Services according to your Personal Preferences.
We use Personal Data and Other Data to personalize the Services and improve your experiences, including when you contact our call center, visit one of our properties or use the Online Services, to:
- Customize your experience according to your Personal Preferences
- Present offers tailored to your Personal Preferences
We will use Personal Data and Other Data to provide personalized Services according to your Personal Preferences either with your consent or because we have a legitimate interest to do so.
Communicate with you about goods and services according to your Personal Preferences.
We use Personal Data and Other Data to:
- Send you marketing communications and promotional offers, as well as periodic customer satisfaction, market research or quality assurance surveys
We will use Personal Data and Other Data to communicate with you with your consent, to manage our contractual relationship with you and/or because we have a legitimate interest to do so.
Loyalty Programs.
We use Personal Data and Other Data to:
- Offer and manage your participation in our loyalty programs, as well as others that are specific to certain properties or tailored to your interests
- Send you offers, promotions and information about your account status and activities
- We will use Personal Data and Other Data in this way with your consent, to manage our contractual relationship with you and/or because we have a legitimate interest to do so.
Sweepstakes, activities, events and promotions.
We use Personal Data and Other Data to allow you to participate in sweepstakes, contests and other promotions and to administer these activities. Some of these activities have additional rules and may contain additional information about how we use and disclose your Personal Data. We suggest that you read any such rules carefully.

We use Personal Data and Other Data in this way with your consent, to manage our contractual relationship with you and/or because we have a legitimate interest to do so.
Business Purposes.
We use Personal Data and Other Data for data analysis, audits, security and fraud monitoring and prevention (including with the use of closed circuit television, card keys, and other security systems), developing new goods and services, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.

We use Personal Data and Other Data in this way to manage our contractual relationship with you, comply with a legal obligation and/or because we have a legitimate interest to do so.

DISCLOSURE OF PERSONAL DATA AND OTHER DATA
Our goal is to provide you with the highest level of hospitality and Services, and to do so, we share Personal Data and Other Data with the following:

Strategic Business Partners.
We disclose Personal Data and Other Data with select Strategic Business Partners who provide goods, services and offers that enhance your experience at our properties if you have requested a booking or service with our Strategic Business Partners. By sharing data with these Strategic Business Partners, we are able to make personalized services and unique travel experiences available to you. For example, this sharing enables spa, restaurant, health club, concierge and other outlets at our properties to provide you with services. This sharing also enables us to provide you with a single source for purchasing packages that include travel-related services, such as airline tickets, rental cars and vacation packages.
Service Providers.
We disclose Personal Data and Other Data to third-party service providers for the purposes described in this Privacy Policy. Examples of service providers include companies that provide website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, marketing, auditing and other services.
Corporate Reorganization.
We may disclose or transfer your Personal Data and Other Data to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of the Listel Hospitality Group business, assets or stock (including any bankruptcy or similar proceedings).

OTHER USES AND DISCLOSURES
We will use and disclose Personal Data as we believe to be necessary or appropriate:

to comply with applicable law, including laws outside your country of residence;
to comply with legal process;
to respond to requests from public and government authorities, including authorities outside your country of residence and to meet national security or law enforcement requirements;
to enforce our terms and conditions;
to protect our operations;
to protect the rights, privacy, safety or property of the Listel Hospitality Group, you or others; and
to allow us to pursue available remedies or limit the damages that we may sustain.

We may use and disclose Other Data for any purpose, except where we are not allowed to under applicable law. In some instances, we may combine Other Data with Personal Data (such as combining your name with your location). If we do, we will treat the combined data as Personal Data as long as it is combined.

NON-LISTEL HOSPITALITY GROUP ENTITIES
This Privacy Policy does not address, and we are not responsible for the privacy, data or other practices of any entities outside of the Listel Hospitality Group, including Strategic Business Partners or any third party operating any site or service to which the Services link, payment service, loyalty program, or website that is the landing page of the high-speed Internet providers at our properties. The inclusion of a link on the Online Services does not imply endorsement of the linked site or service by us. We have no control over, and are not responsible for, any third party’s collection, use and disclosure of your Personal Data.

In addition, we are not responsible for the data collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Data you disclose to other organizations through or the Apps or our Social Media Pages.

SECURITY
We seek to use reasonable organizational, technical and administrative measures to protect Personal Data. Unfortunately, no data transmission or storage system can be guaranteed to be 100% 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 your account has been compromised), please immediately notify us in accordance with the “Contacting Us” section, below.

LINKS TO OTHER WEB SITES:
In order to anticipate your needs, our website provides links to other web sites and third parties for your convenience and information. We are not responsible for the collection, use, maintenance, sharing or disclosure of data (including personal data) by such third parties. We encourage you to contact these third parties to ask questions about their privacy practices, policies and security measures before disclosing any personal data. We recommend that you review the privacy statements and policies of linked web sites to understand how those web sites collect, use and store information.

CHOICES, ACCESS AND RETENTION
You have choices when it comes to how we use your data and we want to ensure you have the information to make the choices that are right for you.

If you no longer want to receive marketing-related emails, you may unsubscribe or opt-out by sending an email to info@listelhotel.com, using the subject line “Unsubscribe”, so indicating your request with sufficient personal identifiers so we can appropriately act on your request. All our marketing communication of this type will also contain instructions for unsubscribing.

We will try to comply with your request as soon as reasonably practicable. If you opt out of receiving marketing emails from us, we may still send you important administrative messages, from which you cannot opt out.

HOW YOU CAN ACCESS, CHANGE OR SUPPRESS YOUR PERSONAL DATA
If you would like to review, correct, update, suppress, restrict or delete Personal Data that you have previously provided to us, or if you would like to receive an electronic copy of your Personal Data for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by law), you can contact us at info@listelhotel.com, or by mail:

Listel Hospitality Group
1300 Robson Street
Vancouver BC V6E 1C5
Attention: Privacy Officer

In your request, please make clear what Personal Data you would like to have changed, whether you would like to have your Personal Data suppressed from our database, or other limitations you would like to put on our use of your Personal Data.

For your protection, we only fulfill requests for 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 fulfilling your request. We will try to comply with your request as soon as reasonably practicable.

Please note that we often need to retain certain data for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or reservation, or enter a promotion, you may not be able to change or delete the Personal Data provided until after the completion of such purchase, reservation, or promotion). There may also be residual data that will remain within our databases and other records, which will not be removed. In addition, there may be certain data that we may not allow you to review for legal, security or other reasons.

Retention
We will retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

The criteria used to determine our retention periods include:

The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services)
Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them)
Whether retention is advisable considering our legal position (such as, for statutes of limitations, litigation or regulatory investigations)

SENSITIVE DATA
Unless specifically requested, we ask that you not send us, and you not disclose, on or through the Services or otherwise to us, any Sensitive Personal Data (e.g., social security numbers, national identification number, data related to racial or ethnic origin, political opinions, religion, ideological or other beliefs, health, biometrics or genetic characteristics, criminal background, trade union membership, or administrative or criminal proceedings and sanctions).

USE OF SERVICES BY MINORS
The Services are not directed to individuals under the age of sixteen (16), and we request that they not provide Personal Data through the Services.

UPDATES TO THIS PRIVACY POLICY
The “LAST UPDATED” legend at the top of this page indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Online Services. Your use of the Services following these changes means that you accept the revised Privacy Policy. If you would like to review the version of the Privacy Policy that was effective immediately prior to this revision, please contact us at info@listelhotel.com

Contacting Us
If you have any questions about this Privacy Policy, please contact us at info@listelhotel.com, or by mail:

Listel Hospitality Group
1300 Robson Street
Vancouver BC V6E 1C5
Attention: Privacy Officer

Because your email communications to us may not always be secure, please do not include credit card or Sensitive Data in your emails to us.

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