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Privacy Policy

Effective 05.25.2018

Welcome!

We take your privacy seriously and know you do too. This Privacy Policy is here to help you understand how we collect, use, disclose, and process your personal data. We also describe your choices and rights with respect to how we process your personal data. Please read this policy carefully.

Who We Are

This is the Privacy Policy of The Broadmoor Hotel, Inc. ( “Broadmoor,” “us,” “our,” or “we”), a Colorado company with offices at 1 Lake Avenue, Colorado Springs, CO 80906. You can contact us here .

Applicability

This Privacy Policy applies to our “Digital Services” which include our:

  • websites that link to/post this Privacy Policy, including any subdomains or mobile versions (the “Site(s)”);
  • 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)”).

Agreement

This policy is incorporated into the Terms of Use governing your use of any of our Digital Services. Any capitalized terms not defined in this Privacy Policy will have the definitions provided in our Terms of Use. Supplemental policies may also apply, such as those located on our “Policies” page.

Following notice to you or your acknowledgement of this Privacy Policy (including any updates), your continued use of any of our Digital Services indicates your consent to the practices described in this Policy.

Third Parties

This Privacy Policy does not apply to information collected by third parties, for example, when you visit a third party website or interact with online advertisements, unless and until we receive your information from those parties. Please review these third-parties’ privacy policies before disclosing information to them. See our list of third parties for information regarding sources and recipients of personal data.

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

Account Registration

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.

Purchases

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.

Marketing Communications

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.

Mobile Apps

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

Data : We may process Identity Data, Preferences Data, and certain Contact Data if you choose to register for special promotions and offers such as discounts, sweepstakes, or contests . Some special promotions and offers are operated/controlled by us, and others are operated/controlled by our third party partners. We may receive this data from third parties to the extent allowed by the partner; otherwise, this Privacy Policy will not apply.

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.

Staffing Data

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.

Uses : Staffing data processed under this Privacy Policy is used primarily for the assessment and creation of the staffing relationship. Subject to Your Rights and Choices, we may also use your Contact Data to process your application, contact your regarding this or other future application/vendor/work opportunities, or similar matters.

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.

On-premise Technology

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.

Note : If you use on-premise WiFi, additional terms and conditions may apply, and we (or our third party provider) may have access to and/or process additional Personal Data. This data may reveal Special Category Data. For more information, please review any other privacy policy related to the services.

Cookies and Similar Technologies

Data : We, and certain third parties, may process Identity Data, Device Data, Contact Data,Preference Data, Location Data, and certain User Content when you interact with cookies and similar technologies. We may receive this data from third parties if allowed by the partner; otherwise, this Privacy Policy will not apply.

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

Personalization

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.

Marketing Communications

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.

Behavioral Advertising

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.

Additional Processing

If we process Personal Data in connection with our Digital Services in a way not described in this Privacy Policy, this Privacy Policy will still apply generally (e.g. with respect to Your Rights and Choices) unless otherwise stated when you provide it.

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.

Data transfers

Generally

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.

Legal disclosures : In limited circumstances, we may, without notice or your consent, access and disclose your Personal Data, 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 legally required, to prevent or respond to a crime, to investigate violations of our Terms of Use, or in the vital interests of us or any person. Note, these disclosures may be made to governments that do not ensure the same degree of protection of your Personal Data as your home jurisdiction. We may, in our sole discretion (but without any obligation), object to the disclosure of your Personal Data to such parties.

International Transfers

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.

Your Rights & Choices

Your Rights

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.

Your Choices

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.

Cookies & Similar Tech : If you do not want information collected through the use of cookies, you can manage/deny cookies (and certain technologies) using your browser’s settings menu. You must opt out of third party services directly via the third party. For example, to opt-out of Google’s analytic and marketing services, visit Google Analytics Terms of Use , the Google Privacy Policy , or Google Analytics Opt-out . Our Site does not respond to your browser’s do-not-track request.

Behavioral Advertising : You may opt out or withdraw your consent to behavioral advertising. You must opt out of third party services directly via the third party. For example, to opt out of Google’s use of cookies, visit Google’s Ads Settings, here . To learn more about how to opt out of DoubleClick’s use of cookies, visit the DoubleClick opt-out page, here . To opt out from Facebook Custom Audience Pixel, visit their customer support page here. To learn more about how to opt out of Twitter’s use of audience pixels, visit the Twitter help page here. If you wish to take steps to opt-out of tracking by certain online advertisers, you can visit the Digital Advertising Alliance’s opt-out page at http://www.aboutads.info/choices or the Network Advertising Initiative at www.networkadvertising.org/optout_nonppii.asp . You can limit or opt out of our processing for behavioral advertising by contacting us.

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.

Security

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.

Data Retention

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.

Minors

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.

Changes to Our Privacy Policy

We may change this Privacy Policy from time to time. Changes will be posted on this page with the effective date. Please visit this page regularly so that you are aware of our latest updates. Your use of the Digital Service following notice of any changes indicates acceptance of any changes.

Contact Us

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)

Note: This list may be incomplete, and is subject to change without notice. Additional or specific parties are identified generally in the Privacy Policy, and specific parties may be identified at the time of a transaction, or vary based on the context of your transaction. Please contact us re: general inquiries for more details on data recipients and sources, or if you have questions.

What Our Guests Are Saying
"The classiest hotel I have ever stayed at. "
— Sammymadison - Trip Advisor
"Beautiful resort, the most incredible service we've ever experienced, all with amazing scenery as well?! What's not to love? "
— Jennifer C. - Facebook
"Awesome doesn't even begin to cover The Broadmoor experience. Five-Star service and accommodations. If you haven't been…GO! "
— Joanne F. - Facebook