Legal information

We may collect "personal information" about you (i.e. information that identifies you or relates to you as an identifiable individual), such as

• Your name
• Your postal address (including billing and delivery addresses)
• Your telephone number
• Your email address
• Your credit or debit card number
• Financial information in some cases
• Your social network account information
• Your holiday or travel information and preferences, such as your preferred facilities, travel dates and number of people or children accompanying you
• Special needs or conditions that may affect your stay
• Your driver's licence, government-issued ID or passport
• Your geolocation information
• Your preferences for communication, products or services
• Demographic information
• Your IP address
• Your account or member ID

We may collect information about you during any interaction between you and us, for example when :

• You use, pay for or register for a product or service
• You send us a question or a request
• You use our Services
• You make a reservation
• You are staying in one of our establishments
• You provide a testimonial or anecdote, or submit an opinion or comment
• You are participating in a competition, prize draw or promotional activity
• You participate in a loyalty programme or any other programme
• You "like", subscribe to, otherwise interact with or post on any of our Social Network Pages

Other information we collect about you :

• Cookie : Our Services may use "cookies" and similar technologies (collectively, "Cookies"). Cookies are small text files sent by the Website to your computer for tracking purposes and stored in a file on your hard drive. Cookies make browsing the Internet easier by saving your preferences so that we can use them again to improve your next visit to our Website.

• One of the purposes of cookies is to simplify the use of the Website. For example, they are used to save the user's login information so that the user does not have to enter it each time.
• Cookies can be defined as "permanent" or "temporary" (or "session"). Permanent Cookies store the user's preferences for a given Website, so that they can be used in subsequent browsing sessions. They are valid until their set expiry date (unless the user deletes them before). Temporary cookies expire at the end of the user's session, when the web browser is closed.
  
  • Cookies are also used for statistical purposes, to determine how the site is used. They may come from us or from third parties. Google Analytics : We use Google Analytics to better understand how this Website is used by people who visit it and to facilitate interest-based advertising associated with your Google Account and other devices you use. The information generated by the Google Analytics Cookie about your use of the Website is transmitted to and stored by Google. If you do not want your activities on this website to be tracked by Google Analytics, you can indicate this preference by clicking on the following link: http://tools.google.com/dlpage/gaoptout?hl=fr.

• Pixels, tags We or third party servers may use tags or web beacons on this Website to count the number of users who visit certain pages. This information is collected and reported in the aggregate. We may use it to improve our marketing programs and content.

• Other sources : We may receive your personal information from other sources, such as public databases and other third parties. Mobile devices : When you access or use our Services with a mobile device, we may collect information such as the unique identifier of the device and your location. Do not track me" signals: For the time being, we do not respond to "do not track me" signals from browsers. We are waiting for feedback from stakeholders and others to develop standards on how to interpret these signals. Third parties, including our service providers, may collect information about your online activities over time and across different websites, including ours. You can find out how to exercise your choice about the collection of information about your online activities over time and on third party sites or through online services at www.aboutads.info and networkadvertising.org.

• Other information - : In addition to any personal or other information you choose to provide to us on the Services, we and our third party service providers may use a variety of technologies developed now and in the future that automatically collect certain information about website usage whenever you visit or interact with the Services. This information may include browser type, operating system, page viewed, time of day, origin of request, previous page viewed and other similar data. We may use this usage information for a variety of purposes, including expanding or improving the Services. In addition, we may collect your IP address or other unique identifier of the device you are using to access the Internet, if any (collectively, referred to herein as a " Device ID "). The Device ID is a number automatically assigned to your device and we can identify your device by its Device ID. When analyzed, Usage Data allows us to determine how our Services are used, including the types of visitors who view the Services, the type of content that is most popular, the type of content you may find most relevant, and the type of visitors who are interested in certain types of content and advertising. We may associate your Device ID or website usage data with the personal information you provide.
  We use non-personal information in a variety of ways, including to analyze site traffic, understand customer needs and trends, conduct targeted promotional activities and improve our services. We may use your non-personal information on its own, or we may aggregate it with information we have obtained from others. We may share your non-personal information with our affiliates and third parties to accomplish these and other purposes. We may also provide our analysis and certain non-personal information to third parties, but this will not involve the disclosure of your personally identifiable information.

Because anonymized information is not personal information, we have the right to use it for any purpose. If we combine anonymised data with personal information, we treat the combined information as personal information in accordance with this Privacy Policy.

We may process personal information relating to any of the following:

2.1. Our commercial transactions with you, including but not limited to:

• To enter into or perform a contract with you
• To answer and satisfy your requests and queries
• To send you administrative information, such as information about the Services or an event you are attending
• To respond to and satisfy any purchase or service request

2.2. In our legitimate business interestsincluding but not limited to:

To personalise your experience of the Services by presenting you with tailored products and offers

• To enable you to enter sweepstakes, contests and similar promotions and to provide these activities (each of which may be governed by additional rules and regulations and may contain additional information about how we handle your personal information)
• To facilitate social sharing of your social network account(s)
• To perform data analysis and audits, monitor and prevent fraud, develop new products, optimize, improve or modify our Services, identify usage trends, verify the use and functionality of our Services, help enforce our terms and conditions, help protect our Services, determine the effectiveness of our promotional campaigns, manage and expand our business
• To protect our operations or those of our Subsidiaries or other third parties
• To protect our rights, privacy, security or property, or those of our Subsidiaries, you or others
• Subject to your marketing preferences and consent, to send you newsletters or marketing communications that we believe may be of interest to you, relating to our own products and services, and on behalf of our Subsidiaries or selected third parties, by post, email, telephone or text message

2.3 In accordance with any consent that you may have granted.

You have the right to refuse to give your consent and, if consent is given, to revoke it at any time.

2.4. To the extent that it is necessary or appropriate for legal reasonsincluding but not limited to:

Under applicable law

• To comply with legal proceedings
• As required by public or government authorities, including in countries other than your country of residence
• To enforce our terms and conditions
• To enable us to pursue available remedies or limit any damages suffered by us, our Subsidiaries or other third parties

If you do not provide us with information that is legally required or necessary for the performance of the contract, you may lose benefits or we may decide not to enter into a contract or render the Services.

We may disclose your information as follows:

• Subsidiaries : To any other entity that is, at the time you disclose your personal information, directly or indirectly controlled by us or under common control with us ("the Subsidiaries ") for the purposes described in this Privacy Policy, including under the section " Why and how do we use your information? "Unless otherwise provided by the applicable law. Suppliers and service providers : We may disclose your information to suppliers and service providers with whom we work in the following areas: travel services, financial services, homeowners associations, travel insurance, website hosting, data analysis, payment processing, order processing, provision of information technology and related infrastructure, customer services, email services, credit card processing, tax and financial advice, legal advice, accounting or audit services.
• Professional partners, sponsors and other third parties We may disclose your personal information to business partners, co-sponsors of promotions and other third parties in order to provide you with services that may be of interest to you. For example, we may share your personal information with owners and managers of affiliated and unaffiliated hotels and resorts, airlines, car rental services, and other third parties to facilitate bookings or to provide products or services to you. We may also co-sponsor promotions, sweepstakes, or other events with a third party and we may share your personal information in connection with these events. In addition, we may share your personal information with third party suppliers located on-site at hotels or resorts (e.g., spa, golf, concierge and restaurants). If you provide additional information to any of these third parties, such information will be subject to their privacy policies.
• Forums : We may make available to users notices, forums, blogs and other such user-generated content systems. All information posted on these systems becomes public information and you should always exercise caution when deciding to disclose personal information. We are not responsible for the privacy practices of other users, including website operators to whom you provide information.
• Merger or acquisition : We may disclose your personal information to a third party who acquires any part of our business or the business of one of our Subsidiaries, whether by merger, consolidation, divestiture, spin-off or purchase of all or substantially all of its assets.
• Disclosure permitted by law : We may disclose your personal information to law enforcement authorities, public or governmental agencies, officials, regulators or any other person or entity with appropriate legal authority to receive your information or justifying such receipt, if we are required or permitted to do so by law or legal process, to respond to complaints or to protect our rights, interests, privacy, and/or those of our Affiliates, you or third parties.

Security of your information : We take reasonable steps to protect the information you provide to us from loss, misuse or unauthorized access, disclosure, alteration and destruction. We have put in place appropriate physical, electronic and managerial procedures to safeguard and secure your information from loss, misuse, unauthorized access or disclosure, alteration and destruction. Unfortunately, no security system is 100 % infallible and therefore we cannot guarantee the security of all information you provide to us through the Services.

• Information provided on behalf of a third party : If you provide us with information about another person, please ensure that they have authorised you to do so for the purposes detailed in this Privacy Policy.
• Links to websites : The Services may contain links to other websites that we do not operate. We do not control how these sites collect your information and we are not responsible for the practices, policies and security measures implemented on these websites. You should read the privacy policies of these other websites before submitting your information to them.
• Social networking sites : Please note that we are not responsible for the collection, use and disclosure policies and practices (including data security) of other organisations such as Facebook, Apple, Google, Microsoft, RIM and other application developers, application providers, social network platform providers, operating system providers, Wi-Fi service providers or device manufacturers, including any personal information you disclose to other organisations via or in connection with the Apps or our Social Network Pages.
• Changes to our Privacy Policy : We may, from time to time, revise this Privacy Policy or use your personal information for new and unanticipated purposes not previously disclosed, in order to adapt to changes in the regulatory or business environment, or to meet the needs of our customers and service providers. Updated dated versions will be posted on the Services. Subject to any provisions of applicable law to the contrary (e.g., regarding obtaining your consent for relevant material changes), the amended Privacy Policy will be effective immediately upon such posting.
• Minors : We do not knowingly collect, maintain or use personal information from persons under the age of 18 and no part of our Websites, Social Networking Pages and Apps is directed to persons under the age of 18. If we accidentally collect or retain personal information from persons under the age of 18, you may request the deletion of such information by contacting us using the contact information provided in the " How to contact us? "below.
• International transfers : As an international company, we may, subject to applicable law, transfer your information to our Subsidiaries or selected third parties outside of the country in which you are located and in locations where information protection standards may be different (e.g., your information may be stored on servers in other jurisdictions). We will use appropriate safeguards regarding the transfer and use of your personal information, such as a European Commission adequacy decision, standard clauses or other applicable adequacy mechanisms. If you would like to know more about the safeguards we have in place, you can contact us directly using the contact details set out in the section " How to contact us?"below.
• Retention period Retention Period: We retain your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

• Changing your marketing preferences : You can opt out of receiving marketing communications from us at any time:
  
  • By using the unsubscribe function in the email we send you; or
  • By contacting us using the contact details in the section " How to contact us? "below.
• Revocation of consent : You may revoke any consent you have provided to us to process your information at any time.
• Access to your information : In accordance with applicable laws, you may access the personal information we process about you.

Any request to access or obtain copies of your personal information must be made in writing by contacting us using the contact information provided in the "Contact Information" section of this Privacy Policy. How to contact us? "You may be asked to confirm your identity and provide further details about your application. We may ask you to confirm your identity and provide further details about your application.

• Correction of your information : We will take reasonable steps to ensure that the personal information we hold about you is accurate. It is your responsibility to ensure that you provide us with true, accurate and complete information and to notify us in a timely manner when this information changes. You may request the correction of any inaccurate or incomplete personal information held by us or on our behalf by contacting us using the contact details set out in the section "Contact Information". How to contact us?"below.
• Deleting your information In some cases, you can ask us to delete your personal information by contacting us using the contact information provided in the "Contact Us" section. How to contact us? "We will evaluate your request and determine whether to delete the information under applicable law. We will evaluate your request and determine, in accordance with applicable law, whether we should delete the information.
• Opposition to the Treatment If you would like us to stop processing your personal information, you can do so by contacting us using the contact details provided in the "Contact Us" section. How to contact us? "below. We will assess your request and determine, under applicable law, whether we have a reason to continue Processing.
• Transferring your information In some cases, you may receive your personal information in a format that allows you to send it to another company or to ask us to transfer it directly to another company.

• Contact details: If, after reading this Privacy Policy, you have any questions, complaints or concerns about the privacy of your data, or if you would like to make any requests relating to your personal information or obtain more information about the safeguards used for international transfers, please send an e-mail to lahulpe.privacy@dolce.com or a letter to :

Dolce La Hulpe Brussels

Attn: Privacy Officer

135, chaussée de Bruxelles

1310 La Hulpe (Belgium)

If you have a complaint or concern about the way we handle your personal information, we will try to find solutions. You may also communicate your complaint or concern to the Belgian Data Protection Authority located at Rue de la Presse, 35, 1000 Brussels (www.privacycommission.be) or another European supervisory authority.

Last revised: MAY, 2018