WHAT IS PERSONAL INFORMATION?
The term “Personal Information” refers to any information that can be used to identify you as an individual. It can include, among other things, your name, address, age, gender, personal financial history and social insurance or social security number.
WHY IS PERSONAL INFORMATION COLLECTED?
1. To Provide Superior Customer Service to our Guests
Personal Information is collected to assist us in making your reservation and providing the services you request at any of our properties, to ensure we meet your needs while you are staying with us and/or to allow us to contact you in relation to matters that arise from your stay with us. By keeping certain stay related Personal Information on file, such as information regarding guest history and itemized spending, guests of Four Seasons have the ability to confirm prior transactions and reconcile statements or invoices.
2. To Keep Our Guests and Owners Informed
We may use the Personal Information you provide to send you newsletters regarding our properties and to advise you of promotions or to inform you of offers or other information that may be of interest to you. In order to do this, your information may be shared with a third party, including a customer relationship management company and/or a marketing and communications company. These companies are under contract with Four Seasons and contractually required to protect all guest information to which they have access. If you do not wish to receive information from Four Seasons Hotels and Resorts you may indicate your wishes on your registration card when you stay with us or you may advise one of our hotels or send an e-mail to: email@example.com
3. For Marketing Research
Finally, we may wish to contact Guests and Owners to conduct surveys or focus groups to receive your views of our properties and service delivery. Such information may be collected by a third party under contract with us and they will be contractually required to protect your Personal Information as explained below. Occasionally we will combine information from a number of Guests and Owners to better understand trends and Guest and Owner expectations. When this occurs, all identifiers are removed and the aggregate information cannot be linked to any specific Guests or Owners.
HOW IS PERSONAL INFORMATION COLLECTED?
1. On Our Web Site
A. Initially Upon Contact With Our Web Site
When you visit our web site, you are initially given a “cookie”, and your computer is assigned an ID number. A cookie is a commonly used device that tracks an individual user’s preferences, and is capable of enhancing your visit to the site. Cookies allow us to provide a customized experience without the visitor having to remind us of his or her preferences each time she or he visits our site. Our cookies do not contain any personally identifying information. Four Seasons cookies also do not follow visitors when traveling on the Internet after leaving the Four Seasons web site.
Once you have visited our web site and accepted our cookie, your ID number is automatically assigned to your computer whenever you visit our web site. Despite the fact that you remain anonymous until you enter Personal Information in the web site, the ID number allows us to log your session, so that we may better assist you should you need some individualized service or support. Once you enter Personal Information on the web site, we associate your ID number with your contact information so we can recognize you on a future visit. We also use it to keep track of information that appears to be of particular interest to you.
B. While Browsing Our Web Site
While in the process of browsing our web site, you also provide us with information that does not reveal your personal identity – what type of destination you’re seeking information about, for example. We use this aggregated, anonymous data mainly for editorial purposes, but we do not connect it to any Personal Information, such as your name or address.
While you explore our web site for the information that interests you, you may wish to put in a specific “Information Request” about one of our hotels or resorts, or you may wish to participate in one of our on-line surveys or promotions. To respond to this request or to participate in our various programs, we may ask you for Personal Information, such as your name, zip/postal code, e-mail address, and phone number.
If you wish, you may also submit your e-mail address in order to be placed on a subscription list or to receive other information. You will be placed on these lists only when you indicate your desire to be included. In deciding whether or not to join such lists, please note that they are only used for internal purposes – we do not sell or rent our lists to anyone. In the event you choose to join one of our lists, you may ask to be removed from the list at any time. Visitors will always have the ability to accept or decline any form of communication from Four Seasons.
C. Making a Purchase on Our Web Site
When making a purchase, such as a gift card, you will be asked to complete a form that includes your contact information and payment information. The form is secure (see below). When the form is complete, your credit card number will be verified using a checking sequence, and once this is confirmed we authorize payment for the amount shown on your order form. Once your transaction is confirmed you will see a ‘Thank You’ screen, and if you requested an e-mail confirmation it will be sent within a few moments. Again, due to the personal nature of the information you give when making a purchase through our web site, the form is secure, such that your credit card number is protected with the most sophisticated encryption technology available and is transmitted on a private network. Purchasing transactions are assisted by third party processors in Canada who are required by contract with us to protect the privacy of your Personal Information.
We retain a log file of transactions at our web site, excluding your credit card number, connected to your ID number. We will then use that information to assist in any inquiries about your transaction. We also occasionally combine information from a number of web visitors in a way that does not identify any user, in order to identify user patterns.
2. When Making a Reservation
A. On Our Web Site
If you decide that you would like to make a reservation at any of our hotels or resorts, you will be linked to our reservation service site. Although it appears to be part of our site, the reservation site is, in fact, provided by Amadeus Travel Distribution, SA which provides an automated reservations and distribution system to the travel industry. We pass your computer ID number on to Amadeus, but they are unfamiliar with you. You can search for rates and availability at our hotels and resorts without providing any Personal Information.
Your credit card number will be verified using a checking sequence, but we do not authorize any payments at this point. Once your reservation is confirmed, Four Seasons will be sent all of the reservation information. From this point the information is sent to the selected hotel in exactly the same way as if you called us directly or if your travel agent made the reservation
Due to the personal nature of the information you give when making a reservation through our web site, the reservation system is secure, such that your credit card number is protected with the most sophisticated encryption technology available and is transmitted on a private network.
We also receive a copy of the reservation profile at our web site excluding your credit card number connected to your ID number. We will then use that information to create a log in our web site database.
We also occasionally combine information from a number of web visitors in a way that does not identify any user, in order to identify user patterns.
B. Through our Worldwide Reservations Offices or Hotels
Reservations can also be made by calling one of our Worldwide Reservation Offices (“WRO”) or by contacting a particular hotel or resort directly. When you make a reservation we may ask you for Personal Information such as your name, address, telephone number and method of payment. We may also obtain from you any room preferences or special requests. Personal Information obtained by WRO will be sent in a secured communication to the relevant hotel. Confirmation of your reservation will be provided to you, generally by e-mail, directly from the hotel or resort.
3. During your stay at a Hotel or Resort
During your stay, we record your itemized spending to properly assemble your folio, which sets out your room rate and other expenses billed to your room. We also record this information to comply with financial reporting requirements, including those imposed by our auditors and government regulators. We may also collect certain information as required by local laws (e.g. passport number). Information particular to your stay may also be stored (i.e. health issues, payment difficulties, special requests, service issues). This stay specific information is stored in the property management system at the particular hotel where you stayed and is combined with information from previous visits that you have made to that hotel. Certain information regarding your service preferences may be made available to other Four Seasons properties through the Four Seasons guest history database. You may advise the Hotel if you do not want personal preferences shared.
In addition, we may retain the content of any document (including letters, comment cards, electronic documents such as e-mails and other similar forms of communication) that you send us before, during or following your stay. This information may be shared with employees of the hotel but will not be shared with any third party.
4. Regarding Residence Clubs
A. When Inquiring about Residence Club Ownership
If you have indicated on our website, in a personal mailing or otherwise that you are interested in receiving information about services and promotions offered by Four Seasons, you may receive information about Four Seasons Residence Clubs. If you contact Four Seasons to request further information about becoming an owner at one or more of our Residence Club properties, we will record your contact information and the list of Residence Club properties about which you would like to receive information. We will then forward this information to one or more of our Four Seasons Residence Club Property Sales Specialists, who will contact you to provide you with the information that you requested.
B. When becoming a Residence Club Owner
C. As a Residence Club Owner
Once you become a Residence Club owner, Four Seasons as manager of the Residence Club, will use your Personal Information to create an owner profile that is stored in our Property Management System. This is used to keep track of your Residence Club account and to provide you with superior service throughout your ongoing relationship with Four Seasons. The information recorded in your Residence Club owner profile includes your name, contact information, credit card number, financial information relating to the purchase of your Four Seasons Residence Club property interest, details about your ownership and use of other Residence Club properties, as well as your preferences and any special requests.
When you contact the Four Seasons World Wide Reservation Office or the Residence Club Property to reserve time at our Property, or for any other reason relating to your Residence Club ownership, the Four Seasons staff who speak to you will access your owner profile on our Property Management System. The information you provide about your reservation and any additional information, requests or preferences will be recorded in the owner profile. This information will be used to assist us in booking your reservation, providing the services that you desire and to ensure we meet your needs while you are staying at your Residence Club Property.
D. During your stay at your Residence Club Property
During your stay at a Residence Club Property, Four Seasons will record information about your use of the Property and the related amenities and services offered by the Hotel or Resort. Four Seasons will use this information for the purposes of billing, and to keep track of reservations of your Property by you and other owners. Four Seasons may also record any information you provide about your preferences as well as information about any issues you encountered during your stay (i.e. health issues, payment difficulties, etc.) in order to provide you with superior customer service during your stay and in our ongoing relationship with you as a Residence Club owner. We also record information about your stay to comply with financial reporting requirements, including those imposed by our auditors and government regulators. We may also collect certain information as required by local laws (e.g. passport number).
In addition, we may retain the content of any document (including comment cards, electronic documents such as e-mails and other forms of similar communication) that you send us before, during or following your stay. This information may be shared with employees of the Residence Club or Hotel but will not be shared with any third party.
5. Regarding Private Residence Ownership
A. When inquiring about Private Residence Ownership
B. As a Private Residence Owner
Once you become a Private Residence owner, Four Seasons as manager of the Homeowners’ Association, will use your Personal Information to create an owner profile that is stored in our Property Management System. This is used to keep track of your account and to provide you with superior service throughout your ongoing relationship with Four Seasons. The information recorded in your Private Residence owner profile includes your name, contact information, credit card number, details about your ownership and use of your Private Residence, as well as your preferences and any special requests.
C. During your stay at your Private Residence
During your stay at your Private Residence, Four Seasons as manager of the Homeowners’ Association, will record information about your use of the amenities and services offered by the Hotel or Resort. Four Seasons will use this information for the purposes of billing. Four Seasons may also record any information you provide about your preferences as well as information about any issues you encountered during your stay (i.e. health issues, payment difficulties, etc.) in order to provide you with superior customer service during your stay and in our ongoing relationship with you as a Private Residence owner. We also record information about your stay to comply with financial reporting requirements, including those imposed by our auditors and government regulators. We may also collect certain information as required by local laws (e.g. passport number).
In addition, we may retain the content of any document (including comment cards, electronic documents such as e-mails and other forms of similar communication) that you send us. This information may be shared with employees of the Private Residences or the Hotel but will not be shared with any third party without your consent.
HOW DO WE STORE PERSONAL INFORMATION?
1. At the Hotel or Resort
Each hotel goes to great measures to ensure that all Personal Information is kept in a secure location, be it a database or filing cabinet. Furthermore, we take steps to ensure that only designated individuals have access to this information.
2. In Our Guest Reservation System
In order to serve you better we also store certain guest information in our Guest Reservation System (“GUESTres”). GUESTres is a secure customer database stored on a dedicated server located in a data centre in Toronto, Ontario, Canada.
The stored information includes guest name, address, phone numbers and credit card number. We may also store certain information regarding your service preferences. When you make a reservation at another Four Seasons property, this information is sent to that hotel or resort.
We also store other transaction information in GUESTres, including the number of stays you have had at properties managed by Four Seasons and the number of nights of each stay. This information may be available to another Four Seasons property when you make a reservation at that property, in order to serve you better.
3. In Our Residence Clubs Owner System
As a Residence Club owner, your Personal Information will be stored in our property management system. This is a secure database stored in a server located in a data centre in Toronto, Ontario, Canada.
The stored information includes your name, contact information, credit card number, information relating to your Residence Club Property ownership and amenities, information relating to your stays at your Residence Club Property and other services offered at that Property, historical billing records and any information you may provide about your particular preferences.
4. In Our Private Residence Owner System
As a Private Residence Owner, your Personal Information will be stored in our property management system on our server located in a data centre in Toronto, Ontario, Canada.
The stored information includes your name, contact information, credit card number, information regarding the services, amenities and preferences connected with your use of your Private Residence, and historical billing records.
5. In Our Marketing Database
Four Seasons maintains a database of Guest and Owner information which is used for marketing, promotion and research purposes. Guests and Owners will only receive such information if they have provided permission on their Hotel registration form, on the Four Seasons web site, or in some other form. Any information sent provides a clear notice of how to discontinue receiving promotional materials.
WHAT INFORMATION IS NOT SECURE?
When you log-in to complete or modify a Booking Profile, Guest Service Profile, your online interaction with us is protected from eavesdropping using the highest level encryption technology based on the browser you use. In order to ensure your privacy and the protection of information you choose to share with us, we allow only encrypted communications from all of our web forms.
It is important to note that any e-mail communication is not secure. This is a risk inherent in the use of e-mail. Please be aware of this when requesting information or sending forms to us by e-mail (for example, from the Contact Us section of our web site). We recommend that you do not include any confidential information (i.e. credit card information) when using e-mail. For your protection, our e-mail responses to you will not include any confidential information.
Finally, to be prudent, please be sure to always close your browsers when you are done using a form or the reservation site. Although the session will terminate after a short period of inactivity, it is best to close your browsers immediately upon completion, since while you are logged on it is easier for someone to attempt to get access to your profile.
IF I HAVE CREATED A GUEST PROFILE, HOW IS MY PERSONAL INFORMATION TREATED?
If you are invited and elect to create a Guest Profile, on our web site, you will be asked to furnish specific Personal Information. You will also be asked to provide a password for use each time you log-in. Once you have created a Guest Profile, we may add online session data to your Guest Profile on subsequent visits to our website. When you provide information, including revised information to your Guest Profile, we may use the information you provide to update other databases maintained by us.
WHAT INFORMATION MAY BE EXCHANGED BETWEEN HOTELS?
Information is shared between certified data privacy personnel at individual Four Seasons hotels in certain limited circumstances, particularly where health or safety concerns have arisen in the past. Preference information may also be shared to enhance your hotel experience. Further, if a guest does not pay the outstanding account on time, or acts in an unlawful manner in regards to payment obligations, this information may be shared among accounting personnel at Four Seasons properties.
WHAT PERSONAL INFORMATION MAY BE PROVIDED TO THIRD PARTIES?
Personal information is shared with third party residential property developers as set out above. The particular developer’s website can be consulted for the developer’s policy on the collection, storage and use of such information.
We will only share Personal Information about you outside Four Seasons Hotels and Resorts without your consent, where: (a) it is required or authorized by law (for example, in response to a legal subpoena); (b) it is required to provide you with services you have requested in which case you will be considered to have implied your consent (i.e. car rental); (c) if your stay has been paid for by a third party we will provide billing information to the paying party; (d) if you have failed to pay amounts owed to a property.
If Four Seasons Hotels and Resorts suspects any unlawful activity is taking place, it may investigate and/or report its findings or suspicions to the police or other relevant law enforcement agency.
HOW DO I ACCESS MY PERSONAL INFORMATION?
We understand that you may like to know what Personal Information we hold about you. We are happy to assist you with your request. To protect your Personal Information, however, we require that you prove your identity to us at the time your request is made. You may make a request to the CIS Leader at the Hotel where you stayed or to the Corporate Guest Historian as set out below.
When you make a request in person, we will require you to produce some form of photo identification such as a passport or a driver’s license and you will be asked to sign a request form.
Where you make a request by other means, we require the request be made in writing via fax or letter including a copy of a government issued identification and signature. We also require home and business addresses and phone numbers so we can check them with our files and satisfy ourselves as to your identity.
The above information is required to create an audit trail of how the request has been handled. Where a request is made, any correspondence or application may be kept and added to your Personal Information.
Four Seasons reserves the right to decline access to your Personal Information under certain circumstances. If your Personal Information will not be disclosed, you will be provided with the reasons for this non-disclosure.
HOW DO I REVISE MY PERSONAL INFORMATION?
If at any time you wish to update or access your Personal Information, you can do so by contacting our Corporate Guest Historian:
via e-mail at firstname.lastname@example.org
via fax at 1 (416) 441-4437
via letter – Attention: Corporate Guest Historian
1165 Leslie Street
Toronto, Ontario M3C 1H9
Or you may visit our web site at www.fourseasons.com
HOW LONG IS MY PERSONAL INFORMATION RETAINED?
Your Personal Information will be stored for the period of time required by law in the jurisdiction of any hotel holding the information. It may be stored indefinitely by Four Seasons as long as there is a business purpose for doing so. From time to time we may delete your Personal Information if you have not stayed with us in a number of years.
HOW WILL I KNOW IF THERE ARE CHANGES TO THIS POLICY?
HOW IS PERSONAL INFORMATION AFFECTED BY BUSINESS TRANSFERS?
Four Seasons Hotels and Resorts manages properties on behalf of third party owners. Guest information required for the business transaction between the guest and the property is shared with the property owner, but all other Personal Information is considered to be proprietary to Four Seasons, and is not shared with property owners. If we cease to manage a particular property, all Personal Information remains with Four Seasons. Guest information that is historically shared with the property owner is retained by the property owner.
WHAT LAWS APPLY TO THIS POLICY?
If you have additional questions regarding the law or if you feel we have not treated your Personal Information appropriately, you may contact The Privacy Commissioner of Canada at the following address:
The Office of the Privacy Commissioner of Canada
112 Kent Street
Canada K1A 1H3
Toll-free number: 1-800-282-1376
Web site: www.privcom.gc.ca
TO WHOM DO I DIRECT QUESTIONS OR CONCERNS REGARDING THIS POLICY?
Chief Privacy Officer
Four Seasons Hotels and Resorts
1165 Leslie Street
Toronto, Ontario M3C 1H9