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PRIVACY POLICY

General Overview

This website or mobile application is one of several sites (the “Sites”) or mobile applications (the “Apps”) (collectively, the “Digital Services”) relating to and/or operated by The Broadmoor Hotel, Inc., its subsidiaries, affiliates and related companies (collectively “Broadmoor” or “we”). The purpose of this Privacy Policy is to disclose to you what information we may collect, how we may collect it, with whom we may share it, and certain other matters related to such information, including the choices you have regarding our collection of information and our use and disclosure to other parties of information we may have collected from you. Terms not otherwise defined herein shall have the meaning ascribed to such terms in the Terms of Use applicable to the Digital Services. 

Except as otherwise discussed in this Privacy Policy, this document only addresses the use and disclosure of information we collect from you online and through our Apps. For some services, we collect and transfer personal information to a service provider, or you may visit other merchants or service providers through links on our Site who may collect and use your personal information. We encourage you to review the privacy policies of these sites before you disclose your personal information to others.
Please read the following to learn more about our data collection policies and practices:

      • Types of information that may be collected. 
 
      • How information is collected. 

      • How we use the information we collect. 

      • With whom the information may be shared. 

      • The choices you have about the collection and use of your information. 

      • The security precautions in place to protect against the loss, misuse, or alteration of your information. 
  
      • Links to other Websites. 

      • International Users. 

      • EU-US Safe Harbor.

      • Limitation of Liability. 

      • Notification of changes and acceptance of the Privacy Policy. 

      • Correcting and updating personal information.
 
      • A special note for parents concerning privacy.

      • Contact information for questions or concerns about this Privacy Policy.

Types of information that may be collected. 

We may collect personally-identifiable information and non-personally identifiable information when you use our Digital Services.  Personally-identifiable information is information that can be used to identify you personally (either alone or in combination with other information), and non-personally identifiable information cannot be used to identify a specific individual.  The personally-identifiable information we collect is used to facilitate the purchase and delivery of information, products or services to our customers and visitors.  Specific personally-identifiable information collected may include, but is not limited to the following and may be subject to change:

  • In the case of a purchase which is completed on one of our Sites, an online credit card transaction is required in order to complete the purchase. During this process we generate and collect certain personally-identifiable information, such as name, name of the credit card holder, credit card billing address, credit card number, credit card security code, credit card expiration date, customer’s shipping address, phone number, and email address. For certain Services in which the transaction processing is managed by a third party service provider, your credit card and related information may be collected by a third party, and may or may not be shared with Broadmoor, depending on the arrangement with that provider.
  • If you wish to receive any of our newsletters or special offers, view or use certain features of our Digital Services, receive text message updates, or participate in any of our contests, drawings, sweepstakes, or promotions, we may require you to complete a form which will require the submission of certain personally-identifiable information, such as name, mailing address, phone number, email address, and potentially other information.
  • We may provide you with the option of registering with us or with a third-party provider to purchase products, make reservations, to comment on our blogs, or to request or reserve services while a guest at our properties. When you register with us or our third-party providers, you or the third party may provide us your name, email address, information regarding your interests in hospitality, travel and leisure as well as certain other information about you and your lifestyle, or a profile may automatically be created in our database if you provide certain information to us.  Providing such information is optional.  However, if a profile is created, we may combine information we receive from you or about you from various sources (including your bookings at our properties, your transactions on our Digital Services, information you provide our other affiliates, or information you provide offline) in your profile.
  • When you use our App, the App may collect your location via GPS if you request directions to/from our properties or nearby attractions, or in order for us to provide other services to you. Further, if you complete a reservation or request for services using the App, we may collect your name, address, credit card information, and if you are staying at one of our properties, your room number, telephone number, and name.
  • If you apply for a job with Broadmoor, you may provide us personal information such as your tax ID number, name, address, background, criminal record, or other sensitive information (including sensitive personal information as defined by EU Directive 95/46/EC). Any information provided in a job application will be managed in accordance with all applicable laws and regulations.


How is information collected?


We may collect information from you in several different ways through our Digital Services, including but not limited to those described below:

Registration.

If you register using one of our Digital Services (whether powered by us or a third-party provider), you will be asked to complete a registration form and provide personally-identifiable information. You may also be asked to choose a user ID and password in order to take advantage of certain features, including, but not limited to, newsletters, contests or other services.  Similarly, if you agree to provide us with optional profile information, this information will be collected through a registration form. You may complete this registration form when you submit a request for proposal for a wedding, meeting, or group event; register with our online stores; or opt-in to receive communications from us.

Newsletters, Site Emails and Mobile Offers.

We may offer newsletters and/or other communications to share information with you about specials or other promotional materials, regarding the Digital Services, about us and our affiliates, subsidiaries, and business partners, or about third party offers or information we think would be of interest to you.  You may receive a these communications either by registering for a particular type of communication, or in conjunction with a special feature or service for which you have registered on the Digital Service. You may cancel your email subscription by following the instructions provided on the Site, in the designated area of the newsletters or emails, or as specified in a communication.  Remember, if you consent to receive texts from us, your wireless carrier may impose a charge on incoming texts.  Please check with your wireless carrier for details.

Paid Transactions.

Certain transactions you may complete using our Digital Services, such as booking a reservation or purchasing items in one of our online stores, may require that you enter your name, email, address, payment information, and other details.  We will use this information to complete the transaction that you have requested, e.g. to process your reservation and to invoice you.  Although some of these services are handled directly by us, others are managed on our behalf by third party service providers, and the information you provide during these paid transactions may be submitted directly to the applicable provider, which in turn may share limited information (such as your name and email address, but not payment account details) with us or our subsidiaries and affiliates. 

Contests or Sweepstakes.

We may operate contests and sweepstakes through the Digital Services, which may require registration in order to enter. Your personally-identifiable information may be used by us to contact you for winner notification, prize delivery confirmation or other promotional purposes. Your entry in the contest or sweepstakes may also result in your being added to our marketing lists as well as those of our promotional partners associated with the contest or sweepstakes. Acceptance of a prize may require you (unless prohibited by law) to allow us to post publicly some of your information on the Digital Services, such as on a winner’s page, in the event you win a contest or sweepstakes. In some instances, a third-party advertiser or sponsor may operate or host a contest or sweepstakes on the Digital Services, and collect your information. In those cases, where we are not the sponsor, operator or host of the contest or sweepstakes, we may have no control over the information collected and accordingly urge you to review the official rules of the contest/sweepstakes as well as the advertiser’s or sponsor’s privacy policy applicable to the contest or sweepstakes before participating.

Surveys or Voting.

From time-to-time we may request personally-identifiable information from you via surveys or voting polls. Participation is voluntary and you will have the opportunity to decide whether or not to disclose information. At times, you may have to register to vote or to take part in a survey.

Cookies and Similar Technologies

Our Sites use “cookies” or similar technologies. Cookies automatically identify your Web browser to the Sites whenever you visit the Sites, and may make using the Sites easier for you by saving certain information so you do not need to re-enter data upon your return to a Site, or may help to provide relevant information to you.  Please read our Cookie Policy  to learn more about how we use cookies and similar technologies, and your choices regarding cookies when you use our Sites.

IP Addresses and Click-stream Data.

We may identify IP addresses and may track click-stream data for purposes of system administration, to improve the Digital Services, to report aggregate information to our advertisers and sponsors, or for other internal uses related to the Digital Services.  An IP address is a number that is automatically assigned to your computer whenever you access the Internet. Our computers identify your computer by its IP address. When you request Web pages from the Sites, our computers log your IP address.

Click-stream data is information collected by our computers when you request pages from the Digital Services. Click-stream data may include such information as the page served, the time, the source of the request, the type of browser making the request, the preceding page view and other such non-personal information. This data helps us analyze how visitors arrive at the Digital Services, what type of content is most popular, what type of visitors in the aggregate are interested in particular kinds of content and advertising, and the like.

How do we use the information we collect?

We internally use personally-identifiable information about our visitors and customers to improve our marketing and promotional efforts, to statistically analyze Digital Service usage, to improve our content and product offerings, to improve the Digital Services and provide better service, and for our other business purposes. We may use your email address and mailing address or phone number in accordance with appliable laws, to contact you regarding administrative matters or notices, issues with a transaction, satisfaction with the Digital Services and/or our products and services, and to provide information regarding offers, events, products or services we believe would interest you. 

We collect, process and use personal information only for the purpose for which it was first collected and, if applicable, as authorized by you, including the uses described in this Privacy Policy or other uses which you may later authorize. We take reasonable steps to ensure that personal information collected is relevant to its intended use, and is accurate, current and complete.  

To whom may the information be disclosed?

Information we collect may be disclosed to a variety of parties, depending upon the purpose for which the information was provided and the context in which it was provided.  When we transfer information to third parties, we use reasonable efforts to assure that they comply with our Privacy Policy and applicable legal requirements. 

If you register with us or our third-party partners, your information (including information related to purchases you make on any of our Digital Services) will be sent to Broadmoor, and aggregated and maintained as part of your profile.  We may access or use such information, and we may share such information with our current or future affiliated and related companies, or carefully selected third parties, to provide you with information or marketing communications in which we think you may be interested (except where prohibited by the privacy laws and opt-in requirements of various countries or the U.S.-EU Safe Harbor Framework, when and to the extent such restrictions are applicable to your information). You may opt-out of having your information shared with any third parties or used for marketing communications by following the instructions below under “What choices do I have about collecting, using, and disclosing my information?”

In order to process your requests, we may provide your personally-identifiable information to service providers or other companies who work on our behalf in order, for example, to process the transaction and deliver the goods or services you have ordered.  If you have been booked on a reservation through a third party travel agent or as part of a group, the reservation may be facilitated through a third party service provider, and in some cases we may not receive any personal information until you arrive on our property.  When we receive your information, we may provide your information as needed to the party who made the reservation.

In addition, in the event that we go through an existing or potential business transition, such as a merger, acquisition, liquidation or sale of all or a portion of our assets, customer information will, in most instances, be part of the assets transferred.

We may, without your consent, access and disclose your personal information, any communications sent or received by you, and any other information that we may have about you to the extent we believe such disclosure is required by law, regulation, rule or court order; pursuant to requests from governmental, regulatory or administrative agencies or law enforcement authorities; or to prevent, investigate, identify persons or organizations potentially involved in, or take any action regarding suspected fraud, violations of our Terms of Use, or activity that appears to us to be illegal or we believe may expose us to legal liability. Additionally, we may disclose personal information in situations that we believe to be emergencies involving potential threats to the physical safety or any person or property if we believe that your information in any way relates to that threat.

What choices do I have about collecting, using, and disclosing my information?

At any time, you may opt-out of having your information provided to third parties for marketing or other commercial purposes, and you may opt-out of other promotional communications from us.  You can unsubscribe from email newsletters or similar communications by clicking on the unsubscribe link in every email (in some cases you may be able to unsubscribe from certain categories and retain other categories of emails, if you wish to do so).  You may opt-out of all information sharing with third parties for marketing purposes, or from receiving communications from us or our affiliated companies, by emailing us at info@broadmoor.com or by sending a letter with your name, mailing address, phone number and email address to the address below.

To obtain a list of the personal information that we hold about you, or for residents of California (as required by California law) to receive a list of the names and addresses of all third parties that received your personal information from us for direct marketing purposes during the preceding calendar year, please send a signed letter with your name, mailing address, phone number and email address to the address below. 

What security precautions are in place to protect against the loss, misuse, or alteration of your information?

We have implemented reasonable security measures to safeguard the personally-identifiable information you provide us. However, please keep in mind that “perfect security” does not exist on the Internet, and accordingly we cannot provide any guarantee that your information will remain secure.

Links to other Websites.

You should be aware that when you use a Digital Service you could be directed to other sites beyond our control. For example, if you “click” on a link to one of our service providers, you will likely leave the Site or App and move to a different website which is not operated by us. This includes links from partners that may use the Broadmoor logo as part of a co-branding agreement. These other websites may send their own cookies to you, independently collect data or solicit personal information and may or may not have their own published privacy policies. If you visit a website that is linked to by a Digital Service, you should carefully review that site’s privacy policy before providing any personal information. This Privacy Policy does not apply to any information you submit to third-party websites, including, without limitation, any websites that may be connected to the Digital Service by hypertext link or otherwise.

International Users.

If you are accessing our Digital Services from outside of the United States, your information will be transferred to us or our service providers in the United States, and you consent to such transfer.  Regardless of where your information is collected or transferred, the information will be treated in accordance with this Privacy Policy.   When we use, process or disclose personal information transferred from the E.U., we comply with the Safe Harbor Privacy Principles as described below, use the European Commission’s approved standard contract clauses, use other approved means under E.U. law to ensure adequate safeguards, or we obtain your consent.  

U.S.-EU Safe Harbor.

We comply with the U.S.-EU Safe Harbor Framework, which relates to the collection, use and retention of personal information collected from users in the European Union. We adhere to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access and enforcement. To learn more about the Safe Harbor program, please visit http://www.export.gov/safeharbor

We will conduct regular reviews of our privacy practices to verify compliance with the U.S.-EU Safe Harbor Privacy Principles and this Privacy Policy. Any questions or concerns about our privacy practices should be sent to the address or email below. We will investigate and attempt to resolve any complaints and disputes regarding the use and disclosure of personal information in accordance with the provisions of this privacy policy. If we are unable to sufficiently resolve any dispute you may have with us, we have agreed to participate in the dispute resolution procedures of the panel established by the EU data protection authorities (DPAs) to resolve disputes pursuant to the Safe Harbor Privacy Principles. EU residents with unresolved complaints may refer them to the EU DPAs’ panel at ec-dppanel-secr@ec.europa.eu or individual EU DPAs (see http://ec.europa.eu/justice/data-protection/bodies/authorities/eu/index_en.htm for contact information of individual EU DPAs).

Limitation of Liability.

By providing us with any personally-identifiable information you expressly and unconditionally release and hold harmless Broadmoor, its parents, subsidiaries, affiliates, related companies and their respective shareholders, owners, members, directors, officers, employees and agents (collectively, the “Releasees”) from any and all liability for any injuries, loss or damage of any kind arising from or in connection with the use and/or misuse of your collected personally-identifiable information. In addition, while we take reasonable steps to prevent third party companies from making unauthorized use of your personal information, we cannot be held be held liable for any injuries, loss or damage of any kind arising from or in connection with the use and/or misuse of your collected personally-identifiable information by those third parties.

Notification of changes and acceptance of the Privacy Policy.

By using any of our Digital Services, you signify your agreement to the terms of our Privacy Policy. We may change this Privacy Policy from time to time. If so, any such changes will be posted on this page, so that the we may keep users informed of its information collection practices. Accordingly, we recommend that you consult this page frequently so that you are aware of our latest policy. Your continued use of the Digital Services shall constitute your acceptance of such revised Privacy Policy.

Correcting and updating personal information.

If your personally-identifiable information changes, you may correct, update or remove the personal data you have provided to us by sending an email to info@broadmoor.com or if you have created an online profile on our Digital Services (typically only applicable in our online stores), by logging in and making changes to your profile online, or by contacting us by mail at the address below.

A special note for parents concerning privacy.

Our Digital Services are not intended for use by children under the age of 13.  We do not knowingly collect personally-identifiable information from children under the age of 13.  If we learn that a child has provided us with personal information, we will delete the child’s personal information (except as may be necessary for legal compliance) and remove the child from any mailing lists.

Whom do I contact with questions or concerns about this Privacy Policy?

If you have any questions about this Privacy Policy, our privacy practices, or your experience with these Digital Services, please contact us as follows:

By mail: 
The Broadmoor
Attn.:  Marketing
1 Lake Avenue
Colorado Springs, CO 80906

By email:  info@broadmoor.com
By online form:  http://www.broadmoor.com/contact-us
By phone: (719) 471-6246

 

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