KEMPA COLLECTION PRIVACY POLICY NOTICE
How We Use Your Personal Information
Thank you for visiting www.kempacollection.com (“Site”). Kempa Collection Ltd. and its affiliates (collectively, “KC”, “We”, “Us”, or “Our”) respect the privacy of the Personal Information (“PI”) of Our customers and visitors to Our Site. The Privacy Policy contained herein is applicable to PI belonging to citizens of the United States and the Cayman Islands. In Our full Privacy Policy below we provide customers and visitors to Our Site with detailed and transparent information regarding the methods we utilize to collect, use, retain, and share PI whenever individuals visit or make a purchase via Our Site. We are committed to protecting the privacy and security of customer and visitor PI; and work diligently to ensure Our privacy policies and procedures are accessible to every Site visitor and customer.
PRIVACY OVERVIEW
Scope of This Policy
This Privacy Statement (“Statement”) explains the Personal Information (“PI”) processing practices of Kempa Collection Ltd. and its affiliates (collectively, “KC”, “We”, “Our”, or “Us”). It applies to any PI you provide to KC and any PI we collect from other sources about you. This Statement is an assertion of Our Privacy Policies regarding your PI. This Statement does not create any rights or obligations on either party, beyond those which already exist under current applicable data protection laws. KC is responsible for the PI (as the controller for the purposes of data protection laws) you share on Our Site. This may also be explained in separate privacy notices made available when your PI is first collected by KC or processed by third-party service providers or vendors (“Third-Party Service Providers”).
NOTE: This Statement does not apply to your use of a non-affiliated third-party site linked to on this Site.
PRIVACY POLICY
1. THIS PRIVACY POLICY
The website located at www.kempacollection.com and various other sites and web pages operated in support of Kempa Collection destinations (collectively, the “Site”) is operated by KC.
This Privacy Policy describes KC’s current policies and procedures regarding PI collected by KC through the Site. This Privacy Policy forms part of the Kempa Collection Website and Social Media Terms of Use [https://www.kempacollection.com/websites-and-social-media-terms-of-use].
2. NOTIFICATION OF CHANGES TO THIS POLICY
KC is continually improving and adding new functionality and features to its Site and improving and adding to Our existing products, services, and programs. Because of the ongoing changes in privacy and cybersecurity laws, and the changing nature of technology, KC’s PI practices will change from time to time. When Our PI practices change, KC will post the changes its Site to notify you of the changes. We encourage you to check this page frequently. This Privacy Policy was last updated on September25, 2020.
3. USE OF SITE VISITOR CUSTOMER PERSONAL INFORMATION
When you register on the Site or make a purchase transaction through a KC booking partner (in any such case, you are referred to herein as a “Customer”), KC may share, your nonpublic PI with others, including KC corporate affiliates (i.e., its parents or subsidiaries) (“Affiliates”), sponsors, affiliates, and partners (collectively, “Affiliated Parties”), and Third-Party Service Providers. In addition, there may be some other, limited circumstances in which KC may be required to share or transfer PI in Our databases, for example, to comply with a legal requirement, to protect your vital interests, or in the event of a corporate sale, merger, reorganization, dissolution, or similar event. KC restricts access to nonpublic PI to those employees and agents who need such information. KC maintains physical, electronic, and procedural safeguards to guard your nonpublic PI.
KC uses PI to enhance your use of KC services by processing information collected for purposes including, but not limited to: providing information to users about KC properties and services; formatting and displaying elements of Contact Data and Message Data to you and those with whom you exchange messages; delivering advertisements and related links; and storing messages.
KC may engage third-party processors to perform functions on its behalf, including sending of newsletters, postal mail, and email; analyzing and processing data; payment processing; and providing customer service. KC requires that the processors agree to use PI in compliance with this Privacy Policy, and in accordance with any other appropriate confidentiality and cybersecurity procedures. The Affiliated Parties may have access to PI needed to perform their functions, but KC will not authorize them to use it for purposes that do not conform to this Privacy Policy. For more information on Our Third-Party Service Providers, see Section 7– Third-Parties below.
If KC intends to use PI for purposes other than as described in this Privacy Policy, KC will offer you the opportunity to opt-out of such use of your PI for those purposes; however, opting-out will impact your ability to utilize the Site and/or book a property. For more information on how to opt-out, see Section 6 – Marketing Opt-Out, below.
Third-Party Service Providers may use Customer PI (de-identified) for statistical or analytical studies or other purposes as allowed by law.
4. PERSONAL INFORMATION COLLECTED
KC or its Third-Party Service Providers collect PI and user data when you use Our Site (exp., Contact Data, Message Data, and Traffic Data (collectively “Customer Information”). PI includes your name, address, email address, passwords, home and business address, phone number(s), and other information that may not be publicly available. “Contact Data” includes information developed by you that may be provided to KC to enhance your use of KC products and services. “Message Data” includes any messages sent or received through the Site, information and data about those messages, your account activity, and your log-in, log-out times. “Traffic Data” includes data about the nature of your usage of the Site and products and services and can include: IP addresses, domain servers, referring/exit pages, operating system, date/time stamp, clickstream data, type of computer or mobile phone, type of web browser, one or more cookies that identify your browser, and telecommunications carrier information.
In connection with your use of the Site, KC or its Third-Party Service Providers may collect: the domain name and/or email address of Site visitors; the email address of users who communicate with KC via the Site or via email; information as to what pages within the Site users access, and for how long the users access or visit such page; information volunteered by the user, such as through registration on the Site, purchases made through the Site, email update requests, and general requests for information; and information about transactions with KC, and third-parties with whom KC affiliates for booking, merchandising, and other commercial purposes.
KC CANNOT GUARANTEE THE SECURITY OF PI ACCESSIBLE ON OR TRANSMITTED VIA THE INTERNET. VLFA PROTECTS THE PRIVACY AND SECURITY OF SITE VISITOR’S AND CUSTOMERS PI USED, COLLECTED, RETAINED, AND SHARED FOR OUR BUSINESS PURPOSES.
5. COOKIES
We and Our Third-Party Service Providers collect information about how you use Our Site, for example what web pages you have viewed in order to analyze trends, generate analytics, provide a better user experience, improve Our services, detect and prevent fraud or security incidents and gather broad demographic information for aggregate use. Our Sites and apps use pixel tags, web beacons, and similar tracking technologies (collectively referred to as “Cookies”) that are created when you use Our online services and are stored on your computer or mobile device. Cookies help Us offer features like storing your purchase selection until you are ready to check out, remembering your login and account settings, recognizing your browser when you visit, and customizing your current and future visits. We also use the information We collect to compile statistics about Our visitors and their use of Our Site to monitor site traffic, develop marketing programs, and improve Our Site design and content. We use the information collected by Our Third-Party Service Providers using Cookies to analyze and track data, improve Our services, determine the popularity of certain content, and better understand Our users’ online activity. Our Third-Party Service Providers may also show you advertisements on other websites and may combine this information with other details those service providers have gathered about your visits to other websites so that the advertisements you receive are more likely to be of interest to you.
6. MARKETING OPT-OUT
As noted in Section 3 – Use of Site Visitor and Customer Personal Information, KC will not provide your nonpublic PI for third-party marketing purposes to Affiliated Parties unless you have opted in to receive emails from the Affiliated Parties. If, at any time, you desire that KC cease providing your nonpublic PI to Affiliated Parties, you may opt out of those disclosures by directing us not to make those disclosures (other than disclosures required by law). If you receive communications from us that you do not want to receive, you may opt out of receiving those communications by clicking the unsubscribe link in the email or emailing us at privacy@kempacollection.com. Occasionally it is necessary to send out a service-related announcement sent by Our Third-Party Service Providers. If you don’t want Our Site to collect information using Cookies, you can change your web browser settings to reject Cookies from the Site or to alert you before a Cookie is placed on your computer. Each browser is different, therefore, check your browser’s “Help” menu to learn how to change your Cookie preferences. If you choose not to accept Cookies, you will not be able to use all the features available to Our Site visitors or customers.
KC honors Do Not Track (“DNT”) signals or use advertising when a DNT browser mechanism is in place.
7. THIRD-PARTIES
a. KC does not disclose PI to third-parties, except when one or more of the following conditions is true:
b. KC has the individual’s permission to make the disclosure;
c. The disclosure is mandatory by professional standards;
d. The disclosure is reasonably related to the sale or other disposition of all or part of KC’s business or assets or in connection with a corporate merger, consolidation, or other corporate reorganization;
e. The personal information to be disclosed is publicly available;
f. The party to whom the disclosure is made controls, is controlled by, or is under common control with KC;
g. The disclosure is reasonably necessary for the establishment or maintenance of legal claims;
h. The disclosure is to persons or entities for whom KC is providing or receiving services, provided the disclosure is consistent with the purpose for which the PI was obtained;
i. KC may share with third-parties certain aggregated, non-personal information and Traffic Data, but such information will not identify you individually;
j. KC may share PI when legally required to do so or at the request of governmental authorities conducting an investigation; or
8. PUBLIC FORUMS
The Site may make chat rooms, forums, message boards, and/or news groups (collectively, “Public Areas”) available to its users. Please remember that any information that is posted to and/or disclosed in these Public Areas becomes public information, and you should exercise caution when deciding to disclose your PI. By posting in the Public Areas you grant KC a license to use the materials you post to the Site or any related service. By posting, downloading, displaying, performing, transmitting, or otherwise distributing information or other content (“User Content”) to the Site or related service, you are granting KC, Our Affiliates, officers, directors, employees, consultants, agents, and representatives a license to use User Content in connection with the operation of the Site, including without limitation: a right to copy, distribute, transmit, publicly display, publicly perform, reproduce, edit, translate, and reformat User Content. You will not be compensated for any User Content. You agree that KC may publish or otherwise disclose your name in connection with your User Content. By posting User Content on the Site or any related service, you warrant and represent that you own the rights to the User Content or are otherwise authorized to post, distribute, display, perform, transmit, or otherwise distribute such User Content.
9. USE OF PERSONAL INFORAMTION CHILDREN UNDER 13 YEARS OLD
KC complies with the United States’ Children’s Online Privacy Protection Act of 1998 (“COPPA”). The KC Site is not directed at children under the age of thirteen. KC does not knowingly collect PI from children under the age of thirteen. If you are under thirteen, please do not transmit any PI without receiving and communicating to KC the required consent of a parent or legal guardian. If you have reason to believe that a child has provided PI to KC, please contact us at privacy@kempacollection.com, and we will delete that information from Our databases.
10. LINK TO OTHER SITES
The www.kempacollection.com Site contains hyperlinks to third-party websites that are not operated by KC or Our Affiliates. The hyperlinks are provided for your convenience only and do not imply any endorsement or association by KC. KC does not control the third-party websites and is not responsible for their PI privacy or security practices. We urge you to review the privacy policy posted on any website you visit before using the website or providing any PI about yourself.
11. CONTACTS
If you have any comments, questions, or concerns about this privacy policy or regarding the method in which KC handles your PI, please contact us at privacy@kempacollection.com.
