Who We Are
mobile applications (the “Mobile App(s)”); and
on-premise or web-enabled technologies, such as on-premise WiFi, Bluetooth beacons, and internet-connected kiosks and devices (the “ Internet and IoT Service(s)”).
Collection and Use of Personal Data
Personal Data We Collect
We may collect and process information that relates to identified or identifiable individuals (“Personal Data”). We collect and process the following categories of Personal Data (note, specific Personal Data elements listed in each category are only examples and may change):
Identity Data : Personal Data about you and your identity, such as your name, ID number, username, and other Personal Data you may provide on registration or purchase forms or as part of an account profile (e.g. biographical information).
Transaction Data: Personal Data we collect in connection with a transaction or purchase, such as the item you purchased, the price, the delivery location, zip code, and other similar information.
Contact Data: Personal Data used to contact an individual, e.g. email address(es), physical address(es), phone number(s), or social media or communications platform usernames/handles, as well as a name or other salutation.
Financial Data: Personal Data relating to financial accounts or services, e.g. a credit card or other financial account number, and other relevant information you provide in connection with a financial transaction.
Device Data: Personal Data relating to your device, browser, or application e.g. IP addresses, MAC addresses, application ID/AdID/IDFA, identifiers from cookies, session navigation history and similar browsing metadata, and other data generated through applications and browsers, including cookies and similar technologies.
Preferences Data: Personal Data relating to your preferences, interests, personal demographics (e.g. location of residence, age group, gender, etc.), your “likes,” and other information provided to us via social media services and advertising technologies, including any other categories of information (such as Transaction Data or Identity Data) linked to such information.
Location Data: Personal Data relating to your precise location, such as information collected from your device’s GPS, or through your interactions with a Bluetooth location beacon, RFID-enabled hardware/wearables, or other localization product.
Special Category Data : As defined in the EU General Data Protection Regulation, this includes Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health information, or information relating to sex life or sexual orientation. (Note: this Personal Data may be subject to additional restrictions.)
Processing of Personal Data
Data : You may be able to register and create an account on our Digital Services. Registration is optional in most cases. If you choose to register, we will process Identity Data, Preferences Data, and Contact Data. We may also process certain Financial Data.
Uses : We use the Identity Data and Contact Data as necessary to create, maintain, and provide you with important information about your account. Financial Data provided at registration will be used only as necessary to process transactions at your request. Subject toYour Rights and Choices, we may also use the Identity Data and Preferences Data as part of our efforts to improve our Digital Services and to create apersonalized user experience, and we may process the Identity Data, Preferences Data, andContact Data in connection with marketing communications and behavioral advertising.
Data : We process Transaction Data,Identity Data, Financial Data,Preferences Data, and certain Contact Data when you complete a purchase on our Digital Services, or for products/services we provide. Note, some purchases are made directly through us, and others are processed by a third party on our behalf. We may obtain any Personal Data processed by a third party on our behalf.
Uses : We use the Transaction Data, Identity Data, and Contact Data as necessary to complete and provide you with important information regarding your transaction. Financial Data is used only as necessary to process your transaction, and we do not permanently store your Financial Data. Subject to Your Rights and Choices, we may process Transaction Data, Identity Data, and Preferences Data to improve our services and create apersonalized user experience, in connection with marketing communications and behavioral advertising.
Data : We may process Identity Data, Device Data, Preferences Data, and Contact Data when you are enrolled to receive, and when you open or interact with, our electronic marketing communications. Note, you may be enrolled with your consent or, where allowed, in connection with account registration or a purchase.
Uses : Subject to Your Rights and Choices, we may use the Identity Data, Device Data, Preferences Data, and Contact Data to improve our services and to create a personalized user experience, and in connection with marketing communications and behavioral advertising.
Data : If you use our Mobile Apps, we may process DeviceData, Preferences Data, and, with your consent, Location Data. Note, you may also be able to complete purchases, register for an account, or enroll in marketing communications through our Mobile App.
Uses : We process the Device Data so that we can optimize the display and functionality of the Mobile App on your device. The Location Data is generally used in order to deliver location-specific content and information through the Mobile App. Subject to Your Rights and Choices, we may use the Device Data, Preferences Data, and Location Data to improve our services and to create a personalized user experience and we may process this Device Data and Location Data in connection with marketing communications and behavioral advertising.
Special Promotions and Offers
Uses : We use this Identity Data and Contact Data as necessary to carry out special promotions and related transactions. Subject to Your Rights and Choices, we may also use this Identity Data and Preferences Data to improve our services and to create a personalized user experience, and we may process this Identity Data and Contact Data in connection with marketing communications and behavioral advertising.
Note : If you win a promotion, your acceptance of a prize may allow us to make certain Personal Information public, e.g. posting your name on a winner’s page. See the applicable program’s terms for details.
Data: We may process Identity Data andContact Data as well as certain Special Category Data in connection with your application to be a vendor, employee, or otherwise join or support our team.
Please note, we may process your Identity Data using automated processes designed to evaluate application criteria or assess applicant information.
User Content & Social Media
Data : We process Identity Data, Preferences Data, Contact Data, and any other data in or relating to your User Content if you choose to submit User Content (e.g. comments, forum and social media posts, etc.) through our Digital Services. If you use a social media service to post User Content that references our official accounts, your comment or content may appear on our Digital Services. We may receive that data from a third party if and to the extent provided to us by a third party (e.g. social media platform).
Uses : We use Identity Data and Contact Data as necessary to carry out the special programs and related transactions. Subject to Your Rights and Choices, we may also use Identity Data and Preferences Data to improve our services and to create a personalized user experience and we may process Identity Data and Contact Data in connection with marketing communications and behavioral advertising.
Note : Any content you provide may be made public as soon as you post it on our Digital Services. We do not screen comments or other postings for personal or inappropriate content.
Data : We process Identity Data, Location Data, Device Data, Preferences Data, and may process Contact Data, when you interact with our Internet & IoT Services. These technologies include proximity beacons, public WiFi networks, RFID technologies, and the like. We may receive this data from third parties (e.g. an operator of our Internet & IoT service) to the extent allowed by that party.
Uses : We use Identity Data, Location Data, Device Data, and Contact Data to enable certain features and to enhance the security of our Sites and Mobile Apps. Subject to Your Rights and Choices, we may process Identity Data, Location Data, Device Data, Preferences Data, and Contact Data to improve our services and to create a personalized user experience and we may process this data to contact you in connection with marketing communications and behavioral advertising.
Cookies and Similar Technologies
Uses : We use Device Data and Identity Data to enable you to register with and/or use certain features of these technologies. Subject to Your Rights and Choices, we may use Identity Data, Location Data, Device Data, and Contact Data to improve our services and to create a personalized user experience and we may use Identity Data, Location Data, Device Data, and Contact Data for marketing communications and behavioral advertising.
Note: Some of these technologies can be used by us and/or our third party partners to identify you across platforms, devices, sites, and services. Third parties may engage in behavioral advertising using this data. Our Cookies, Web Beacons, and Tracking Technologies Policy provides more information about our use of these technologies.
Specific Processing Purposes
Consistent with our legitimate business interests, we may personalize our Digital Services. To do so, we may link together and analyze the Personal Data that we hold about you. Personal Data processed for personalization purposes, whether or not linked, may be augmented with Preferences Data. We may create Preferences Data, or obtain it from third parties, using Personal Data we hold about you. We process Preferences Data so that our communications and Digital Services are more relevant to you. For example, we may greet you by name, provide better recommendations to you, tailor content and communications to your interests, and use the information to guide overall improvements to our products and services. We may also use Preferences Data in connection with behavioral advertising. See Your Rights and Choices for information about how you can limit or opt out of this processing.
Consistent with our legitimate business interests, we (or if appropriate, our affiliates or trusted third parties) may send you marketing and promotional communications to the extent allowed by law if: you sign up for such communications, purchase products or services from us or an affiliate, register on our Digital Services or for a promotion or contest, or in connection with your communications with, or submission of User Content to, us. These communications may be personalized. See Your Rights and Choices for information about how you can limit or opt out of this processing.
We, and certain third parties operating on or through our Digital Services, may engage in online behavioral advertising. This form of advertising includes various parties and service providers, including third party data controllers, engaged in the processing of Personal Data in connection with advertising: This form of advertising uses Preferences Data, Device Data, Identity Data, and at times, Contact Data in order to deliver more relevant advertising to you. The parties that control the processing of Personal Data for behavioral advertising purposes may build a profile of you containing this information, and may be able to identify you across sites, devices, and over time. These services may also track whether you view, interact with, or how often you have seen an ad, or whether you complete a purchase for a good or services after viewing an advertisement. In some cases, these parties may also develop and assess aspects of a profile about you to determine whether you are a type of person a company wants to advertise to, and determine whether and how ads you see are effective, and may augment your profile with information derived from these observations. See Your Rights and Choices for information about how you can limit or opt out of this processing.
Note that we may, without your consent, also process your Personal Data on certain public interest grounds. For example, we may process information as necessary to fulfil our legal obligations, to protect the vital interests of any individuals, or otherwise in the public interest. Please see the data sharing section for more information.
Information we collect may be shared with a variety of parties, depending upon the purpose for and context in which that information was provided. We generally transfer data to the following categories of recipients:
Service Providers: In connection with our general business operations, product/service improvements, to enable certain features, and in connection with our other legitimate business interests, we may share your Personal Data with service providers who provide certain services or process data on our behalf.
Affiliates : In order to streamline certain business operations, improve personalization, share certain promotions and content, and develop products and services that better meet your interests and needs, we may share your Personal Data with our current or future affiliated entities, subsidiaries, and parent companies.
Partners : We may share your Personal Data with business or marketing partners in connection with promotions, events, products, and services that are promoted, managed, supported, or otherwise undertaken with that third party. If appropriate, these parties may engage in direct marketing or behavioral advertising.
Marketers : In order to improve personalization, deliver more relevant information and advertisements, and develop better products and services, we may share certain Personal Data with affiliates and trusted third parties for marketing, advertising, or other commercial purposes, and we may allow our affiliates and other third parties (such as Facebook, ad exchanges, data management platforms, or ad servers) to operate on our Digital Services and process data for behavioral advertising.
Social media: If you use any social media plugin, API, or other similar feature, use a hashtag or similar link, or otherwise interact with us or our Digital Services via social media, we may make your post available on our Digital Services or to the general public. We may share, rebroadcast, or redisplay Personal Data or other information in the post to the extent permitted by the relevant social media service.
Corporate events: Your Personal Data may be processed in the event that we go through a business transition, such as a merger, acquisition, liquidation, or sale of all or a portion of our assets. For example, Personal Data may be part of the assets transferred, or may be disclosed (subject to confidentiality restrictions) during the due diligence process for a potential transaction.
We operate and use service providers located in the United States. If you are located outside the U.S., your Personal Data may be transferred to the U.S. The U.S. does not provide the same legal protections guaranteed to Personal Data in the European Union. Accordingly, your Personal Data may be transferred to the U.S. pursuant to the EU-U.S. Privacy Shield Framework, the Standard Contractual Clauses, or other adequacy mechanisms, or pursuant to exemptions under EU law.
EU-U.S. Privacy Shield
We comply with the EU-U.S. Privacy Shield Framework set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data from European Union member countries. We have certified that we adhere to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. Furthermore, we require third party recipients of EU residents’ Personal Data to agree to respect these principles, and we accept liability for third parties’ processing of EU residents’ data to the extent required by law.
Your Rights & Choices
Subject to the rights granted to other individuals, and our rights to limit or deny access/disclosure under applicable law, you have the following rights in your Personal Data. Note, we may require that you provide additional Personal Data to exercise these rights, e.g. information necessary to prove your identity. You may exercise your rights by contacting us:
Access: You may receive a list of your Personal Data we process to the extent required and permitted by law.
Rectification : You may correct any Personal Data that we hold about you to the extent required and permitted by law. For Registration Data, you may be able to make changes via your account settings menu.
Erasure: To the extent required by law, you may request that we delete your Personal Data from our systems.
Data Export : To the extent required by applicable law, we will send you a copy of your Personal Data in a common portable format of our choice.
Direct Marketing : Residents of California (and others as required by applicable law) may request a list of Personal Data we have disclosed about you to third parties for direct marketing purposes during the preceding calendar year. This request must be written, signed, and mailed to us.
Regulator Contact: You have the right to contact or file a complaint with regulators about our processing of Personal Data. To do so, please contact your local data protection or consumer protection authority.
It is possible for you to use some of our Digital Services without providing any Personal Data, but you may not be able to access certain features or view certain content. You have the following choices regarding the Personal Data we process:
Consent : If you consent to processing, you may withdraw consent any time, to the extent required by law.
Direct Marketing: You have the choice to opt-out of processing related to marketing communications or to withdraw your consent if the marketing communication was initiated through consent. You may exercise your choice via the links in our communications or by contacting us re: direct marketing.
Location Data : You may control or limit Location Data that we collect using our Mobile App and Internet and IoT Services by changing your preferences in your device’s location services preferences menu, or through your choices regarding the use of Bluetooth, WiFi, and other network interfaces you may use to interact with our Digital Services. However, please note that use of RFID technologies may be necessary for the functioning of hardware you must use.
Profiling & Personalization: You may opt out of the creation or other processing of Preferences Data by automated means, and object to processing for personalization purposes, to the extent applicable law gives you the right to do so. To exercise this right, please contact us re: data rights requests. Note that we may not be required to cease processing based solely on an objection.
Other processing: You may have the right under applicable law to object to our processing of your Personal Data for certain purposes. You may do so by contacting us re: data rights requests. Note that we may not be required to cease processing based solely on an objection.
We follow and implement reasonable security measures to safeguard the Personal Data you provide us. However, we sometimes share Personal Data with third parties as noted above, and we do not have control over third parties’ security processes. Please note, we do not warrant perfect security and we do not provide any guarantee that your Personal Data or any other information you provide us will remain secure.
We retain information for so long as it, in our discretion, remains relevant to its purpose, and in any event, for so long as is required by law. We will review retention periods periodically.
Our Digital Services are neither directed at nor intended for use by minors under the age of majority in the relevant jurisdiction. Further, we do not knowingly collect Personal Data from such individuals. If we learn that we have inadvertently done so, we will promptly delete it. Do not access or use the Digital Services if you are not of the age of majority in your jurisdiction unless you have the consent of your parent or guardian.
Feel free to contact us with questions or concerns using the appropriate address below.
General inquires : info@Broadmoor.com
Physical address : The Broadmoor
1 Lake Ave.
Colorado Springs, CO 80906
Attn: VP of Sales and Marketing
List of Third Parties
Unaffiliated Parties and Partners
The following is a list of unaffiliated third parties with whom we may share data or which may engage in processing:
Data sources: Booking.com (online booking vendor)
Domestic Tour Operators (tour and booking group)
Expedia (online booking vendor)
Hotels.com (online booking vendor)
Preferred Hotels and Resorts (referrals, booking)
Travelocity (online booking vendor)
Trip Advisor (promotion and booking service)
Various International and Domestic Tour Operators and Travel Agencies
Data recipients: Cendyn (CRM partner)
Navis (CRM system)