Last Updated: February 3/30/ 2023
LRMB Hotels and Resorts (“LRMB”, “we”, “us” or “our”) takes the issue of safeguarding your privacy seriously. Our Privacy Notice describes what personal information we collect from or receive about you and the ways in which LRMB uses that information.
LRMB collects and handles the personal information of the following categories of individuals:
This Privacy Notice has been adopted by all of the distinct legal entities that manage and operate LRMB Private Residence properties around the world (each a “Property”, and collectively referred to as “Properties”). A complete list of such entities, and additional information relevant to LRMB’s processing of personal information, is available. Those entities include LRMB Hotels Limited, its direct and indirect subsidiaries and affiliates, and all the separate and distinct legal entities that manage LRMB Properties. References to “we”, “us”, “our” or “LRMB” throughout this Privacy Notice refer collectively to those separate and distinct legal entities, or to individual entities, depending on the context.
What personal information do we collect?
Personal information is any information that may identify or relate to you as an identifiable individual. The personal information that we collect or receive about you could include the following categories of information:
How do we use your personal information?
For each of the categories of personal information described above, we use your personal information for the following purposes:
We will combine information from a number of our Guests and/or Owners as well as visitors to our Sites to better understand trends and your expectations. When this occurs, all identifiers are removed and the aggregated information cannot be linked to any specific individual or household and is therefore no longer personal information.
On what bases do we use your personal information?
We use your personal information on the following bases:
How and from what sources do we collect personal information?
For each of the categories of personal information and purposes described above, we gather information when you provide it to us directly, or otherwise interact with us, for example:
We also collect your personal information while monitoring our technology tools and services, including email communications sent to and from LRMB and the use of the chat functionality on our Sites.
We may also receive information about you from other sources. These include our business partners and trusted third party service providers. For example, we receive information about you when you use the LRMB Online Shop (shop.LRMBs.com), which is operated on our behalf by a trusted third party provider. The sources also include other members of your traveling party or other individuals (for instance, an authorized travel agent or personal assistant), as well as information that is made publicly available on the internet such as your picture, which we may use for recognition purposes to provide customer service when you visit our properties. We may also combine information that we have about you from various sources, including the information that you have provided to us.
We, or our third party partners, may use the data collected through cookies and similar technologies to remember information about you for the following purposes: so that you will not have to re-enter it on our Sites; to provide custom, personalized content and information; to identify and contact you across multiple devices; to provide and monitor the effectiveness of our Sites; generate analytics; to diagnose or fix technology problems; to detect or prevent fraud or other harmful activities; to personalize and enhance your experience and to improve the effectiveness of our Sites, offers, advertising, communications and customer service, and otherwise to plan for, optimize and enhance our online services.
How do we protect personal information?
We use a variety of physical, technical, and organizational security measures and technologies to help preserve the integrity and security of your personal information, consistent with applicable data protection and privacy laws. Such measures include but are not limited to adopting monitoring and governance policies and processes, technical and physical access controls, use of encryption technologies, employee training, and our systems’ regular audit and maintenance.
We endeavor to protect the privacy of your online account and internal profile, and other personal information that we hold in our records. Still, unfortunately, we cannot guarantee complete security. Unauthorized access or use, hardware or software failure, and other factors may compromise the security of user information. Also, while we endeavor to put adequate contractual protections in place, we cannot guarantee the security of any personal information in databases hosted by third parties.
It is important to note that any email communication is not secure. This is a risk inherent in the use of email. Please be aware of this when requesting information or sending forms to us by email (for example, from the “Contact Us” section of lrmb.com). We recommend that you do not include any confidential information (such as credit card information) when using email. For your protection, our email responses to you will not include any sensitive personal information.
Finally, to be prudent, please be sure to always close your browsers when you are done using a form or making an online reservation. Although the session will terminate after a short period of inactivity, it is best to close your browsers immediately upon completion, especially when using a public computer or a private computer in a public setting.
Will personal information be provided to third parties?
For each of the categories of personal information described above, we may share certain of your personal information with:
Where a third party engaged by LRMB processes personal information on our behalf, LRMB takes steps to contractually require those parties to protect your personal information in a manner consistent with the principles articulated in this Privacy Notice.
In the case of third-party residential property developers, please visit the particular developer’s privacy notice to learn more about the personal information practices of the third-party developer.
If you have chosen to join a subscription list, please note that such lists are only used for internal purposes, and we do not sell or rent our subscription lists to third parties for their direct marketing purposes.
If LRMB suspects any unlawful activity is occurring, it may investigate and/or report its findings or suspicions to the police or other relevant law enforcement agency.
We may also disclose information as may be required by law or legal process or if we reasonably believe such disclosure is necessary to comply with legal process or the reasonable requests of law enforcement or to exercise or protect the rights, property, or personal safety of LRMB, our guests or owners, or others.
Will your personal information be transferred outside your home country?
Your personal information may be processed by LRMB and its third-party service providers anywhere in the world, including in countries where data privacy laws may not be equivalent to, or as protective as, the laws in your home country.
In particular, your personal information will be stored in your guest profile in our central reservation system located in the USA and is available to all LRMB Properties.
We will implement appropriate measures to ensure that your personal information remains protected and secure when transferred outside your home country. These measures include data transfer agreements implementing standard data protection clauses and transmitting data in accordance with applicable legal requirements. To request additional information regarding these data transfer agreements, please contact our Chief Privacy Officer (see the “Contact us” section below).
What rights do you have regarding your personal information?
Depending on the applicable law, which may be determined by your country, region, or state of residency, you may be able to exercise one or more of the following rights relating to our processing of your personal information. You may also have other rights under the laws of your jurisdiction of residence.
To protect your privacy, we may require that you prove your identity to us when your request is made. This may involve providing information we hold on to file about you (for example, a home or business address) or information regarding your past stays at LRMB Properties.
Accessing, correcting, or deleting your personal information
We understand that you may wish to know what personal information we hold about you or request that we correct or delete certain information. We are happy to assist you with such requests.
LRMB reserves the right to decline a request to access, correct, or delete your personal information under certain circumstances as permitted by applicable law. In particular, there may be various legitimate business reasons or legal obligations that allow or require us to retain your personal information.
Right to decline marketing communications.
If you do not wish to receive marketing communications from LRMB, you can send such a request via email to: [email protected] or, at Properties where consent is collected on registration cards, you may indicate your wishes on your registration card. You will always be able to accept or decline any form of marketing communication from LRMB. You may unsubscribe from electronic marketing communications at any time by selecting the “unsubscribe” link included in such communications. Please note that you may be unable to opt out of service-related communications (such as account verification emails, transactional communications, and technical and security notices).
You may also be entitled to:
Where you are given the option to share personal information with LRMB, you can always choose not to do so.
If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw that consent, we will respect that choice in accordance with our legal obligations.
This could mean that we are unable to perform the actions necessary to achieve the purposes of processing described above (see “How do we use your personal information?”) or that you are unable to make use of the services we offer.
After you have chosen to withdraw your consent, LRMB may continue to process your personal information to the extent required or otherwise permitted by law.
If at any time you wish to exercise any of these rights, you can do so by:
For hotel and resort Guests, contact our Corporate Guest Historian:
or contacting our Director of Residences at your home Property or by using any of the methods described immediately above.
Alternatively, you can contact our Chief Privacy Officer via the details in the “Contact us” section.
You may request an authorized agent (such as a lawyer). We may request evidence of their authority to act on your behalf.
For how long is my personal information retained?
Your personal information will be stored for the period required or permitted by law in the country in which it is stored, including the jurisdiction of any Property holding the information. This may involve retaining information following your stay. We will delete your personal information once it is no longer reasonably necessary for any of the purposes described in this Privacy Notice.
We will also keep your personal information where we need to do so in connection with a legal action or an investigation involving LRMB.
Any financial information LRMB retains will be protected under the terms of this Privacy Notice and, where financing is arranged in the United States, under the Financial Services Modernization Act.
How is personal information affected by business transactions and/or transfers?
LRMB manages Properties on behalf of third-party property owners. LRMB may disclose to such a property owner certain Guest or Owner information as needed to implement business transactions between the Property and a particular Guest or Owner. All other personal information is considered to be proprietary to LRMB and is not shared with property owners. If we cease to manage a particular Property, the property owner will retain guest information required to process pending reservations and information that was historically shared with the property owner. All other personal information remains with LRMB.