Privacy Policy

1 Introduction

This privacy policy (the “Policy”) lets you know how Peninsula Hospitality Group (PHG), its direct and indirect subsidiaries, its affiliates, and the separate and distinct legal entities that manage, operate, franchise, license, own and/or provide services to the various locations operating under or in connection with a Peninsula Hospitality group collect, use, and share your personal information. This Policy gives effect to our commitment to protect your personal information and has been adopted by all of the affiliates, subsidiaries, and all of the separate and distinct legal entities that make up PHG, as defined in this Policy. Note that this Policy does not address or apply to the processing of personal information undertaken by the Apple Leisure Group companies and the definition of “PHG,” “us,” or “we” PHG .

We use your personal information in order to fulfill our commitment to providing an unparalleled guest experience in connection with all of your interactions with PHG (the “Purpose”). As part of that undertaking, we are committed to safeguarding the privacy of the personal information that we gather.

As one of our guests or someone else with whom we interact, you understand and consent that we may collect, use, and share your personal information in accordance with this Policy.

Where you provide to us personal information about another person, you should ensure that person acknowledges this Policy and, in particular, tell him/her how we may use his/her information. You should remind that person to read this Policy in advance and may also give him/her a copy of this Policy.

2 The Application of this Policy

This Policy applies when you interact with PHG either through our websites – including Peninsulagroup.ae and our various booking sites – (collectively, “Websites”), our mobile applications – including PHG – (collectively the, “Applications”), in person, such as when you visit us at PHG Locations (as defined below), or when you communicate with us by phone, text, direct message, social media, or other similar functionality. This Policy also applies to the personal information about you that we receive from a third party, unless specifically covered by such third party’s privacy policy or PHG’s Privacy Policy for Employees.

The term “PHG Locations” includes the various locations affiliated with PHG that operate under or in connection with the PHG brands around the world and also includes independently branded locations affiliated with Peninsula Hospitality group and/or its direct and indirect subsidiaries. The use of the ® symbol designates marks that are registered with the Indian . Patent and Trademark Office, and such marks may also be registered with the trademark offices of certain other territories/countries.

While this Policy is intended to describe the broadest range of our information collection, processing and sharing activities globally, some activities may be more limited in some jurisdictions based on the particular laws or regulations in those territories/countries. For example, the laws of a particular territory/country may limit the types of personal information we can collect or the manner in which we process that information. In those instances, we adjust our internal policies and/or practices to reflect the requirements of local law.

This Policy applies unless there is a specific territory/country privacy policy for you based on your citizenship/residency or if the PHG Location is in such territory/country or if the PHG Privacy Policy for Employees applies.

3 Information We May Collect

The term “Personal Information” in this Policy refers to information collected and maintained (in any form, paper or electronic) that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. We collect and process your Personal Information in order to provide you the best experience possible when you interact with us. The information we collect may vary by territory/country or by your preferred method of interaction with us. The categories of Personal Information that we may collect include:

Contact and Identification Information: We may collect information such as your name, contact details (e.g., phone number(s), address, or email) professional title, employer or professional affiliations, passport and visa information and information from other government IDs;
Account Information and Marketing Preferences: We may collect your account details and credentials for the PHG frequent guest program and any frequent flyer or travel partner program. We may also collect information on your marketing preferences;
Stay and Purchase Information: We may collect information such as the hotels where you have stayed or booked a stay, dates of arrival and departure, goods and services purchased or utilized at PHG Locations or on the Website or Application, physical and digital room key usage, special requests made, service and stay preferences (including room and vacation preferences), telephone numbers dialed and faxes sent, calls or messages received, and any feedback or content you provide to us regarding your stay. We may also collect information through the use of closed-circuit television systems, Internet systems (including wired or wireless networks, smart or mobile device, or your location), and other security and technology systems;
Device, Internet & Network Activity: We may collect the Internet Protocol (“IP”) address automatically assigned to your computer or device each time you interact with us online. We may also collect information from your devices if they connect to, or are detected by, the wireless networks at our properties. We or our vendors might also collect information about how you use Wi-Fi networks and other services, such as the websites you visit while using our Wi-Fi network. We also use cookies and related technologies to collect information related to how you interact with our Websites, Applications, and online content. Depending on your settings, we may collect the date and time of your visit, the pages you access and the amount of time you spend on each page, the type of Internet browser you use, your device’s model, manufacturer and operating system, your search terms on the Website, the URL of any websites that you visited before and after visiting our Websites (including the advertisement that referred you to our Website), and whether you click or interact with our digital content and advertising on our Websites and other sites. We may also use technologies to record user sessions on our Websites and Applications. When you access the Application or the mobile version of the Website, we collect your device, your device’s unique identifier, your mobile network information, and the type of browser you use. We may also embed technologies (which may include, for example, web beacons, tags, and pixels) in the emails and other communications we or our vendors send to you to help us understand how you interact with those messages, such as whether and when you opened a message or clicked on any content within the message. For information about how PHG uses cookies and related technologies and how to disable such cookies and related technologies, please see Section 8.2 below;
Payment and Credit Information: We may collect credit card and other payment method details. In limited cases, we may also collect information relating to the credit of customers;
Location Information: We may automatically collect information about your precise geolocation when you access the Website or Application to the extent permitted by applicable law. We may also collect information about your general location using your IP address and your postal code;
Demographic Information: We may collect demographic information, such as your gender, nationality, age, and date and place of birth;
Biometric, Health-related or other Sensitive Personal Information: We may collect Sensitive Personal Information such as health-related or religion information you provide us to fulfil special requests (e.g., health or religious conditions that require specific accommodation or services), or biometric information, such as information used for facial recognition;
Audio and Visual Information: We may record our customer service calls and security footage of our properties, which may include your voice and/or image;
Preferences and Inferences: We may collect your preferences or make inferences about you, reflecting what we believe to be your preferences, characteristics, and predispositions, based on other Personal Information we have; and
Device Content: With your permission, we may collect information relating to the content on your device. For more information, see Section 9.

There may be instances in which the Personal Information that you provide to us or that we collect is considered Sensitive Personal Information under the privacy laws of some territories/countries. Depending on the applicable law, “Sensitive Personal Information” can mean Personal Information from which we can determine or infer an individual’s racial or ethnic origin, political opinions, religious beliefs or other beliefs of a similar nature, membership in a trade union or professional, religious, philosophical, or political association, physical or mental health or condition, medical treatment, genetic data, biometric information, and information about an individual’s sexual orientation. In some very rare instances, financial records, credit card information and location data may constitute Sensitive Personal Information where you are located. If we rely on consent to process your Sensitive Personal Information, you have the right to withdraw that consent at any time. We only process Sensitive Personal Information in your jurisdiction if and to the extent permitted or required by applicable law (e.g., so that we can ensure we tailor our services to you accordingly in terms of food allergies and medical conditions, to ensure we can process card payments). We will seek to protect such information rigorously using the security standards further described below.

When you consent to this Policy you are, to the extent required and permitted under your local law, granting your express and written consent to the processing of any Personal Information that you provide to PHG that is considered to be Sensitive Personal Information or financial information (except, in some jurisdictions, where we will ask that you grant that consent separately). Save to the extent required by law, you are not obliged to provide PHG with any of your Sensitive Personal Information, and should you choose not to, this will not prevent you from purchasing any products or services from PHG (except in locations where credit card information may constitute Sensitive Personal Information).

4 How We Collect Your Personal Information

We collect the above-referenced categories of Personal Information from the following categories of sources:

Directly from you: Much of the Personal Information we process is information that you or someone acting on your behalf directly provides to us. For example, you may provide us with Contact and Identification Information, Stay and Purchase Information, Payment Information, Demographic Information, and Health-related Information, when you create an account; book a reservation; complete surveys, sweepstakes, contests or promotional offers; contact customer service; use our complimentary Wi-Fi; or contact us via email, text, or chat, over the phone, in person, or through third parties.
From your devices and our networks: We use cookies and related technologies to passively collect Personal Information from and across your devices when you interact with the Website, Application, our emails, or other online content or when your device connects to, or is detected by, the wireless networks at our properties.
From other businesses or individuals: We work with business and marketing partners and social media platforms that give us Personal Information about you that they have collected either directly or indirectly from you. We also use features that let your friends and family give us your Personal Information, for example when a family member or friend checks in on your behalf. We also may receive your Personal Information from (i) someone acting on your behalf, such as your travel agent or your employer (where your employer books travel for you), (ii) your travel provider, such as an airline, or (iii) your third-party card or loyalty scheme provider. We may also offer device- or operating system-based authentication as a log-in method of accessing certain services. In those instances, we are notified as to whether the authentication was successful.
From social media: If you post to one of our pages on a social media site, we may receive Contact and Identification Information, Stay and Purchase Information, Internet and Network Activity, and any other Personal Information contained in your social media posts or profile.

5 How We Use Your Information

Subject to applicable laws and the Digital Personal Data Protection ACT, 2023, we may collect, use, and disclose your Personal Information in order to:

provide, charge for, and manage hotel accommodation and other goods and services;
provide you with customer support and a better or more personalized level of service at PHG Locations as well as through the Website, Application, frequent guest program (e.g., Peninsula Hospitality Group®), third-party applications, products or services, or through products or services PHG develops in the future;
allow us to evaluate, analyze, and improve the functionality of our Websites, Applications, or goods and services;
facilitate concierge services on your behalf (e.g., restaurant, attraction and transportation transactions);
administer loyalty, travel, or discount programs and the PHG frequent guest program
administer contests, sweepstakes, or other promotions;
fulfill contractual obligations to you, anyone involved in the process of making your travel arrangements (e.g., travel agents, group travel organizers, or your employer) and vendors (e.g., credit card companies, airline operators, and third-party loyalty, travel, or discount programs);
conduct market research, customer satisfaction and quality assurance surveys;
conduct marketing and sales promotions and serve targeted advertising for products, services, events, or promotions you might be interested in, including those provided by the PHG and by other parties. Where permitted by law, we may work with other companies to serve advertisements or marketing that we think you may find relevant and useful. This may include advertisements displayed on our own Websites or Applications, contained in emails or other communications sent by us, or advertisements from us displayed on other companies’ websites. The advertisements you see may be based on information collected by us or third parties and/or may be based on your activities on our Websites, Applications or third-party websites;
provide for the safety and security of staff, guests, visitors and others;
prevent, detect, and investigate fraud, cyber incidents, or other illegal or harmful activity;
communicate with you about our relationship, such as updates to this Policy or other important legal or business changes;
administer general record keeping;
meet legal and regulatory requirements or compliance obligations;
test and evaluate new products and services;
process credit applications;
fulfill other purposes as disclosed to you in accordance with applicable law or with your consent; and
use certain pieces of Personal Information to verify your identity if you make requests regarding your Personal Information pursuant to this Policy. The verification steps and the pieces of Personal Information that we request may vary depending on the sensitivity and nature of your request.

PHG uses and retains your Personal Information for as long as is necessary to fulfil the purpose for which it is being processed, and in line with our legal and regulatory obligations and risk management guidelines. Following the necessary retention period, PHG will dispose of your Personal Information per our policies and procedures.

There are Closed Circuit Television (CCTV) cameras in operation within and around our hotels and other premises, which, depending on the respective country and applicable laws, may be used for the following purposes:

to assist in protecting the health and safety of PHG guests and staff;
to assist in managing and protecting PHG’s property and the property of PHG’s staff, guests, and other visitors; and
(to the extent permitted by law) for quality assurance purposes.

5.1 Basis of Processing

When we process your Personal Information as one of our guests or someone else with whom we do business, we process that information on the basis of one more of the following legal bases depending on the circumstances: (i) our legitimate interests (as detailed above), (ii) because of legal obligations we are subject to, (iii) because the information is required to fulfill contractual obligations either to you, to anyone involved in making your travel arrangements (e.g., travel agents, group travel organizers, or your employer) and/or to vendors (e.g., credit card companies, airline operators, and third-party loyalty, travel, or discount programs), or (iv) with your consent.

6 Disclosures of your Personal Information

From time to time, we may disclose your Personal Information. We would always make that disclosure in accordance with applicable law. In some jurisdictions, data privacy laws may require us to obtain your consent before we disclose your information to third parties. When you consent to this Policy, you are, to the extent required and permitted under your local law, granting your consent to the transfer of your Personal Information to such third parties for the purpose and to the extent stated in this section and as described in Section 5 above (except, in some jurisdictions, we will ask that you grant that consent separately).

Circumstances where we might make such disclosure (in addition to those described in Section 5 above and Section 8 below) include:

6.1 Peninsula Hospitality Group

We may disclose your Personal Information to other organisation within the PHG and the for the purposes described in this Policy, including for providing you with PHG and for administering membership/loyalty programs.

6.2 Our Agents, Service Providers, and Suppliers

Like most international hotel brands, we may outsource the processing of certain functions and/or information to third parties. When we do outsource the processing of your Personal Information to third parties or provide your Personal Information to third-party service providers, we oblige those third parties to protect your Personal Information with appropriate security measures.

6.3 Reservations and Other Requests at Third Party Locations

Our services, including Peninsulagroup.ae, allow you to make requests for reservations and other items or services with third parties, including hotels that are not PHG Locations (but not affiliated with PHG, through an alliance with the PHG program, , and locations affiliated with other brands through which PHG rewards can be obtained from time to time), Where you make such a request, we will pass information about your request that you provide to us, along with information about your account, to the third party. The information we provide to these third parties will be handled in accordance with their own privacy policies and procedures, and not PHG.

6.4 Consumer Insights

Where we hold Personal Information about you, we may disclose this Personal Information to other companies that may also hold information about you. These companies may combine the information in order to better understand your preferences and interests, thereby enabling them and us to serve you better. If your Personal Information is used for direct marketing purposes, you have the right to object to that by contacting us using the contact information provided under Section 14 below. Further information about how we conduct direct marketing may be found at Section 10 below.

6.5 On-Property Companies

We may share your Personal Information with companies and other organisations that own and manage the spas, restaurants, health clubs, and other outlets at PHG Locations so they can provide you with their services in relation to your stay or visit to such outlet;

6.6 Credit Authorization

When you request credit, your Personal Information will be used and disclosed to appropriate third parties in accordance with applicable laws for the purpose of determining whether to grant and maintain a line of credit to you.

6.7 Business Transfers

As we continue to develop our business, we may sell hotels and other assets, or cease being the manager or franchisor of a PHG Location. In those circumstances, we may include the Personal Information collected about you, or control of that Personal Information, as a business asset in any such transfer. Also, in the unlikely event that we, or substantially all of our assets, are acquired, Personal Information collected about you, or control of such information, may be one of the transferred assets.

Similarly, we may disclose your Personal Information to a third party whom we acquire in order to facilitate mergers and acquisitions of our business and for the furtherance of the purposes described in Section 5 above.

6.8 E-Folio Program

If you are an employee or independent contractor of a company that participates in PHG’s E-Folio Program, and you use the corporate credit card that is provided to you by your employer (if you are an employee) or corporate client (if you are an independent contractor) to pay for your hotel bill at a PHG property, then you may benefit from PHG’s E-Folio Program.

Under the E-Folio Program, an extract of your bill (including the dates of your stay, your credit card details and amounts incurred at the PHG property including room charges and all incidental charges including but not limited to food, beverage, and entertainment charges) will be transferred electronically by the PHG property via PHG’s based information system either to PHG or to a third-party service provider located in the who acts on PHG’s behalf to compile the extract and transfer it to:

the credit card network operator, the credit card issuer and/or their respective subcontractors, who will, in turn, forward that extract to your employer or corporate client (and/or their respective subcontractors) to facilitate the processing and tracking of your travel-related expenses; or
in some limited circumstances, your employer or corporate client (and/or their respective subcontractors) directly for the same purpose.

. The third-party service provider who acts on PHG’s behalf to compile the extract will be subject to contractual provisions meeting the requirements of PHG’s binding corporate rules.

Once the Personal Information is transferred to the credit card network operator, credit card issuer, your employer or corporate client and/or their respective subcontractors, it is no longer subject to the protections described in this Policy, but rather your own arrangements with your employer or corporate client, the relevant credit card network operator and/or the relevant card issuer.

6.9 Legal Requirements

Subject to applicable laws, we reserve the right to disclose any Personal Information we have concerning you if we are compelled to do so by a court of law or lawfully requested to do so by a governmental entity or if we determine it is necessary or desirable to comply with the law or to protect or defend our rights or property in accordance with applicable laws. We also reserve the right to retain Personal Information collected and to process such Personal Information to comply with accounting and tax rules and regulations and any specific record retention laws.

7 International Transfers of Personal Information

Like most international businesses, we have centralized certain aspects of our data processing activities in accordance with applicable laws, which, in many instances, will result in the transfer of your Personal Information from one country/territory to another. For example, if you make a reservation and/or stay at one of the PHG Locations outside India, the Personal Information gathered in that process will be transferred to and processed in accordance with PHG’s binding corporate rules (where they apply to you – for more information about our binding corporate rules, please see Section 14 below). The jurisdictions where that information will be processed may or may not have laws that seek to preserve the privacy of Personal Information. Nevertheless, whenever your Personal Information is transferred within the PHG companies, your Personal Information will be processed in accordance with the terms and conditions of this Policy and applicable laws. A list of the main PHG Locations and entities to which your Personal Information may be transferred, and the jurisdictions in which those entities are located, can be found by selecting “All” at www.peninsulagroup.ae

Additionally, some of the third-party suppliers to which we transfer your Personal Information may be based in different locations, some of which may have lower standards of data protection than in your home country/territory. When we do transfer Personal Information to such third parties, we ensure appropriate safeguards (such as entering into data transfer agreements based on clauses approved by major regulators – such as standard contractual clauses) are in place, and oblige those third parties to protect your Personal Information with appropriate security measures. These third parties broadly fall into two groups: (i) locally provided suppliers supporting individual PHG Locations or groups of PHG Locations, who may operate in any of the countries/territories in which PHG Locations operate; or (ii) centrally-procured service providers, supporting PHG as a whole, who may be located in our major business locations

In some jurisdictions, data privacy laws may require us to obtain your consent before we transfer your information from your originating country/territory to other countries/territories. When you consent to this Policy, you are, to the extent required and permitted under your local law, granting your consent to the transfer of your Personal Information to such other countries/territories for the purpose and to the extent stated in this section and as described in Section 5 above (except, in some jurisdictions, where we will ask that you grant that consent separately).

8 Interacting with Us Online

If you interact with us online, you may wish to know the following:

8.1 You Can Browse Without Revealing Who You Are

You can visit our Websites without logging in or otherwise revealing who you are.

8.2 Cookies and Other Tracking Technologies

We and other parties use cookies, pixels, beacons and other technologies on our Websites, c Applications, and email and marketing messages. These technologies are used to improve our products and services, and for marketing, and they also allow us, advertising networks, social media companies, and other providers, to place and serve advertisements and customized content.

Some of our Websites allow you to manage your cookie preferences by clicking on the Cookie Center link that may be in the footer of those Websites. Choices you make regarding cookies are website, device, and browser specific, and are deleted whenever you clear your cookies or your browser’s cache. This means you need to adjust your cookie preferences on each website, device, and browser you use. If you block cookies, you will not be able to use all of the features of our Websites, including the customization features associated with creating a user profile.

Further information about cookies and related technologies and how they work is available at allaboutcookies.org.

Our Applications may contain software development kits (SDKs) provided by other parties which may collect and transmit information, including for purposes of enabling features in the Applications. We may also collect device advertising identifiers. You can configure your mobile device privacy or advertising settings via your iOS or Android device to limit how applications track certain activity for advertising purposes. Choices you make are device specific.

8.3 Social Media

Our websites may also contain plug-ins and other features that integrate third-party social media platforms into our Websites. You will be able to activate them manually. If you do so, the third parties who operate these platforms may be able to identify you, they may be able to determine how you use this Website and they may link and store this information with your social media profile. Please consult the data protection policies of these social media platforms to understand what they will be doing with your personal data. If you activate these plug-ins and other features, you will be doing so at your own risk.

8.4 Creating a User Profile

You can create a user profile on our Website to, among other things, facilitate your online transactions, and to tailor your experience on our Websites to your interests. This allows us to make more appropriate recommendations to you. We may use the information you provide in your user profile to populate other databases maintained by us and our service providers, as applicable and to the extent permitted by law. By creating a user profile, you are consenting that we may use the Personal Information you provide for these purposes.

You can view, update or remove any Personal Information that you have provided to us for inclusion in your user profile by amending your user profile online or emailing info@peninsulagroup.ae. If you subsequently elect to remove your user profile (or any Personal Information in your profile), we reserve the right to use any Personal Information previously provided by you for inclusion in your user profile for record keeping and quality assurance purposes (unless we are required by law to delete or cease to process or use your Personal Information). Even if you choose not to create a user profile, you can still use our Websites to search for and purchase services.

8.5 Links to Other Websites

If you visit our Website and decide, for example, to purchase a gift certificate, make an airline reservation, rent a car, submit award request forms or apply for a job online, you may be seamlessly linked to websites maintained by third parties with whom we have contracted to provide those services. If you click on a link found on our Websites or on any other website, you should always look at the location bar within your browser to determine whether you have been linked to a different website. This Policy, and our responsibility, is limited to our own information collection practices. We are not responsible for, and cannot always ensure, the information collection practices or privacy policies of other websites maintained by third parties or our service providers where you submit your Personal Information directly to such websites. In addition, we cannot ensure the content of the websites maintained by these third parties or our service providers, even if accessible using a link from our Websites. We urge you to read the privacy and security policies of any external websites before providing any Personal Information while accessing those websites.

8.6 Security

Because the security of your Personal Information is important to us, we require Transport Layer Security (“TLS”) software in order to encrypt the Personal Information that you provide to us. When using TLS, your transmission of Personal Information to us online is encrypted. You can verify whether your Personal Information is transmitted using TLS encryption by confirming the symbol of a closed lock or solid key inside your browser address bar. You can also verify that your Personal Information will be encrypted using TLS encryption by making sure that the prefix for the web address listed for that page has changed from “http” to “https”. If you do not see the appropriate symbol and/or the “https” prefix, you should not assume that the Personal Information that you are being asked to provide will be encrypted prior to transmission.

The Personal Information we collect from you online is stored by us and/or our service providers on databases protected through a combination of physical and electronic access controls, firewall technology and other reasonable security measures. Nevertheless, such security measures cannot prevent all loss, misuse or alteration of Personal Information and we are not responsible for any damages or liabilities relating to any such incidents to the fullest extent permitted by law. Where required under law, we will notify you of any such loss, misuse or alteration of Personal Information that may affect you so that you can take the appropriate actions for the due protection of your rights.

8.7 Minor Children

Our Websites do not sell products or services for purchase by children and we do not knowingly solicit or collect Personal Information from children. You may only use the Site if you are at least eighteen (18) years of age and can form legally binding contracts under applicable law. The Site is not intended for and should not be used by minors. If you are under the age of eighteen (18) or unable to form legally binding contracts under applicable law, you may contact a hotel directly for assistance.

9 Applications

When you download or register to use one of our Applications, you may submit Personal Information to us such as your name, address, email address, phone number, date of birth, username, password and other registration information, financial and credit card information, personal description and/or image.

Further, when you use our Applications, we may collect certain information automatically, including technical information related to your mobile device, your device’s unique identifier, your mobile network information, the type of mobile browser you use and information about the way you use the Application.

Depending on the particular Application you use and only after you have consented to such collection, we may also collect information stored on your device, including contact information, friends lists, login information (where necessary to allow us to communicate with other applications at your request), photos, videos, location information or other digital content. Further details of the kinds of information we collect is set out in the privacy notice for each individual Application.

10 Choice

You always have certain choices regarding what Personal Information you wish to provide to us. However, if you choose not to provide certain details, some of your experiences with us may be affected (for example, we cannot take a reservation without a name).

If you provide us with your contact details (e.g., postal address, email address, telephone number or fax number), we may contact you to let you know about the products, services, promotions and events offered that we think you may be interested in, to the extent permitted by applicable law. We may also share your Personal Information with carefully-selected third parties, who may communicate directly with you, to the extent permitted by applicable law. In some jurisdictions, data privacy laws may require us to obtain a separate consent before we do so. You can always choose whether or not to receive any or all of these communications by contacting us as described in Section 14 below or following the “unsubscribe” instructions contained in the communications.

If you have an account with our frequent guest program , we ask you to indicate your communication preferences at the time you apply for membership or when you create your user profile. We may also ask you to indicate how you would like to receive any offers, marketing and promotional information (e.g., via email or regular mail) and whether you would be willing to participate in surveys. Once you have indicated your preferences, you can always change them.

In some jurisdictions, in addition to you consenting to this Policy, data privacy laws may require us to obtain a separate consent before we send you information that you have not specifically requested. In certain circumstances, your consent may be implied (e.g., where communications are required in order to fulfil your requests and/or where you have volunteered information for use by us). In other cases, we may seek your consent expressly in accordance with applicable laws (e.g., where the information collected is regarded to be Sensitive Personal Information under local regulations).

We will abide by any request from you not to send you direct marketing materials. When such a request is received, your contact details will be “suppressed” rather than deleted. This will help ensure that your request is recorded and retained unless you provide a later consent that overrides it.

11 Updating or Accessing Your Personal Information and Your Other Privacy Rights

With some limited exceptions, you may access and update Personal Information held about you. If you want to inquire about any Personal Information we may have about you, any information we may have shared, or about the consequences of exercising any of your rights, you can do so by clicking here, or by sending us a written request by letter or email to the addresses set out in Section 14 below. Please be sure to include your full name, address and telephone number and a copy of a document evidencing your identity (such as an ID card or passport) so we can ascertain your identity and whether we have any Personal Information regarding you, or in case we need to contact you to obtain any additional information we may require to make that determination. Where you make more than one request in quick succession, we may respond to your subsequent request by referring to our earlier response and only identifying any items that have changed materially.

Depending on applicable law, you may request that we anonymize, block, correct, delete, and/or stop or restrict processing or using Personal Information that we hold about you by clicking here, or by sending a letter or email to the addresses set out in Section 14 below. If we agree that the Personal Information is incorrect, or that the processing should be stopped, we will delete or correct the Personal Information. If we do not agree that the Personal Information is incorrect we will tell you that we do not agree, explain our refusal to you and record the fact that you consider that Personal Information to be incorrect in the relevant file(s).

Depending on applicable law, you may also withdraw your consent, exercise your right to data portability and request that the rules on processing of your Personal Information are explained by sending a letter or email to the addresses set out in Section 14 below.

If you are unhappy with the way we have handled your request, you can escalate your concern to the Chief Privacy Officer by sending an email to info@peninsulagroup.ae

12 Local Privacy Rights

12.1 California Privacy Rights

If you reside in California, you may also make the following more specific requests with respect to your Personal Information in accordance with applicable law:

Access– You can request, that we disclose to you the categories of Personal Information collected about you, the categories of sources from which the Personal Information is collected, the categories of Personal Information sold or disclosed, the business or commercial purpose for collecting, selling or sharing the Personal Information, the categories of third parties with whom we disclose the Personal Information, and the specific pieces of Personal Information collected about you.

Correction –You can request that we correct inaccurate Personal Information that we maintain about you.
Opt-out of Sale or Sharing –You can request to opt out of the sale or sharing of your Personal Information to or with an outside party by sending us a written request by letter or email to the addresses set out in Section 14 below. We and other parties may use cookies and other technologies for advertising purposes, which could constitute a sale or sharing of your Personal Information. Please note that if you make a request to opt-out of sale or sharing and you would like to opt out of such tracking for behavioral advertising purposes, update your cookie preferences by clicking on the Cookie Center link that may be in the footer of our Websites. For more information, please see Section 8.2 above. Your opt-out of cookie-based tracking for advertising purposes is specific to the device, website, and browser you are using, and is deleted whenever you clear your cookies or your browser’s cache. This means you need to adjust your cookie preferences on each website, device, and browser you use. For purposes of this Section, “sell” means the sale, rental, release, disclosure, dissemination, availability, transfer, or other oral, written, or electronic communication of your Personal Information to an outside party for monetary or other valuable consideration and “sharing” means disclosure of Personal Information to third parties for cross-context behavioral advertising purposes, each subject to certain exceptions in applicable law. Please note that after you opt-out of sale or sharing, your use of our Websites may still be tracked by PHG and our service providers. We do not knowingly sell or share the Personal Information of minors under 16 years of age.

As is the case for all consumers regardless of residency, we will not discriminate against you because you exercised any of these rights.

California residents can exercise these access, deletion, or correction rights online by clicking by emailing or calling us using the contact information in Section 14. We may deny certain requests, or fulfil a request only in part, based on our legal rights and obligations. For example, we may retain Personal Information as permitted by law, such as for tax or other record-keeping purposes, to maintain an active account, and to process transactions and facilitate customer requests.

We will take reasonable steps to verify your identity prior to responding to your requests. The verification steps will vary depending on the sensitivity of the Personal Information and whether you have an account with us.

California residents may designate an authorized agent to make a request on their behalf. When submitting the request, please ensure the authorized agent is identified as an authorized agent and ensure the agent has the necessary information to complete the verification process.

For purposes of California residents exercising these rights, please note the following regarding how we collect, and use and disclose your Personal Information as described in this Policy, including in the previous 12 months:

We may collect, disclose and use for our business and commercial purposes, the following categories of Personal Information as set forth in applicable California law: Identifiers; California customer records (such as birthdate, contact information, and payment information); characteristics of protected classifications under California or federal law (such as demographic information like age and gender); commercial information (such as booking history and preferences); biometric information; professional or employment information; education information; Internet or other electronic network activity information; geolocation data; audio, electronic or visual information; and inferences. Please see Section 3 of this Policy for more details about the information we collect.
We may collect the following categories of Sensitive Personal Information: government identification information such as driver’s license or passport number; biometric information; precise geolocation data; citizenship; and health related data.
We collect and use the above categories of Personal Information for the business and commercial purposes described in Section 5 of this Policy.
We collect these categories of Personal Information from the sources described in Section 4 of this Policy.
We may disclose each of these categories of Personal Information for our business and commercial purposes described in Section 5 of this Policy to the extent permitted by applicable law with the categories of parties described in Section 6 and Section 8 of this Policy.
We may sell the following categories of Personal Information: Identifiers; California customer records; demographic information; commercial information; Internet or other electronic network activity; geolocation data; and inferences. We may sell or share these categories of Personal Information to or with the categories of parties described in Section 6 and Section 8 of this Policy, including for the advertising, promotional, and other purposes described in Section 5 and Section 8 of this Policy.

From time to time, we may collect Personal Information in connection with a promotion, offer, program, or discount. The offers and incentives made available through them are generally related to the value of the relationships that we have with the individuals who participate. Participation is voluntary and you may withdraw at any time by emailing us using the information set forth in Section 14 below.

If you reside in California, you also have the right to ask us one time each year if we have shared Personal Information with third parties for their direct marketing purposes. To make a request, please write to us using the contact information provided under Section 14 below. Indicate in your correspondence that you are a California resident making a “Shine the Light” inquiry.

12.2 Nevada Privacy Rights

If you are a Nevada resident, you can request that we not “sell” your “covered information” (as defined in applicable Nevada law). To make such a request, email us using the information set forth in Section 14 below. Please use “Nevada Do Not Sell” in the subject line.

12.3 Virginia Privacy Rights

If you reside in Virginia, you may also make the following more specific requests with respect to your Personal Information in accordance with applicable law, and subject to applicable exceptions set forth in such applicable laws:

Access: You can request, by emailing us that we confirm whether or not we are processing your Personal Information and to obtain a copy of the Personal Information that you provided to us.

Deletion: You can request that we delete Personal Information we have about you, by emailing us

Correction: You can request that we correct inaccurate Personal Information we maintain about you.

Opt-Out of Targeted Advertising: We may use Personal Information obtained from your activities across unaffiliated sites to send more relevant advertising to you. You can request that we stop using your Personal Information for such targeted advertising, by clicking here and updating your cookie preferences by clicking on the Cookie Center link that may be in the footer of our Websites. Additionally, you can opt out of certain uses of cookies for advertising purposes by visiting For more information, please see Section 8.2 above. Your opt-out of cookie-based tracking for advertising purposes is specific to the device, website, and browser you are using, and is deleted whenever you clear your cookies or your browser’s cache.

Opt-Out of Sale: You may request to opt-out of the “sale” (as defined in applicable Virginia law) of your Personal Information

Virginia residents can exercise these rights by following the instructions above or by emailing or calling us using the contact information in Section 14.

We may deny certain requests, or fulfil a request only in part, based on our legal rights and obligations. You have the right to submit an appeal if you are not satisfied with the outcome of your request by sending an email to info@peninsulagroup.ae with “Virginia Appeal” in the subject line.

12.4 Brazil Privacy Rights

If you reside in Brazil or otherwise subject to the Federal Law nº 13.709/18 (“LGPD”), you are entitled with several rights in respect of your Personal Information under LGPD, especially the ones provided under Article 18. In addition to the rights granted to you in Section 3 and Section 11 above, you may also exercise the following rights when applicable:.

Right to Withdraw Consent –You have the right, when the basis for processing is consent, to withdraw the consent at any time, through an easy to use and free of charge procedure.
Right to Revision of Automated Decision Making –Under this right, you may request the revision of decisions taken solely on the basis of automated processing of your personal data which affects your interests, including decisions intended to define personal, professional, consumer or credit profile or aspects of your personality, providing clear and adequate information regarding the criteria and procedures used for an automated decision, subject to our commercial and industrial secrecy.
Right to Petition –You may petition with the Brazilian regulatory authority as well as consumer protection entities regarding the processing of your personal data.

Brazilian residents can exercise these rights in accordance with this Section 12.4 as well as Section 11 and Section 14 by

Lawfulness of Processing: We process your Personal Information, and Sensitive Personal Information, on the legal bases described in Section 3, Section 5 and Section 5.1.

Transfers of your data to countries outside Brazil: If your Personal Information is subject to the PHG will take all necessary measures to ensure that transfers out of Brazil are adequately protected as required by applicable data protection law and in accordance with Section 7.

12.5 China Privacy Rights

This Policy, as updated from time to time, is inclusive of the laws of the People’s Republic of China.

12.6 Japan Privacy Rights

If you reside, are located, or are booking a property in Japan, this Policy gives effect to our commitment to protect your personal information and has been adopted by PHG and the legal entities who own and operate” throughout this Policy, depending upon the context, refer to these hotels.

For a list of PHG to which we may disclose your information for the purposes described in this Policy, including providing you with PHG Services, and for administering membership/loyalty programs, please see Section 6.1 above.

For a list of third parties to which we disclose your Personal Information for outsourced processing, please see Section 6.2 above.

For a list of companies to which we may disclose Personal Information that may also hold information about you, please see Section 6.4 above.

12.7 South Korea Privacy Rights

If you reside, are located, or are booking a property in South Korea, this Policy gives effect to our commitment to protect your Personal Information and has been adopted by the legal entities who own and operate PHG refer to these hotels.

For a list of Peninsula Hospitality Group to which we may disclose your Personal Information, please see Section 6.1 above.

For a list of third parties to which we disclose your Personal Information for outsourced processing, please see Section 6.2 above.

For a list of companies to which we may disclose Personal Information that may also hold information about you, please see Section 6.4 above.

13 Changes to this Policy

Just as our business changes constantly, this Policy may also change. To assist you, this Policy has an effective date set out at the end of this document.

14 Request for Access to Personal Information/Questions or Complaints

If you have any questions about this Policy, about the processing of your data described, or any concerns or complaints with regard to the administration of the Policy, or if you would like to submit a request (in the manner described in Section 11 above) to exercise your rights in relation to the Personal Information that we maintain about you, please contact us by any of the following means:

by calling one of the following toll-free reservation numbers located at the Customer Service page;
by mail at PHG, Attn: 310 Shaikh Khalifa Bin Zayed St; or
by contacting the front desk at any of our locations.

If you are not satisfied with the response that you receive, you can escalate your concern to the Chief Privacy Officer by sending an email to info@peninsulagroup.ae

While this Policy alone does not create contractual rights, PHG has ensured compliance with some of its legal obligations in some countries/territories in relation to Personal Information by creating a set of binding standards and policies (known in some countries/territories as binding corporate rules), approved by a number of national privacy regulators. As a result, depending on your circumstances and location, you may be able to enforce your privacy rights using those standards or policies through that regulator or a court. If you would like to know more about these standards and policies, please contact PHG at the address above or the Chief Privacy Officer at the email address above.

All requests for access to your Personal Information must be submitted in writing by letter or email. We may respond to your request by letter, email, telephone or any other suitable method.

Effective Date:

In the event of any inconsistencies between the English version of this Policy and any version of this Policy in any other language, the English version shall prevail.

Any dispute arising of this Policy shall be subject to Mumbai Jurisdiction.

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