“Personal Data” are data that identify you as an individual or relate to an identifiable individual. We collect the following Personal Data: 

• Your contact information (e.g., name, telephone number, email address, postal address);

• Your financial information (e.g., credit card number, card verification value (CVV) / security code, expiration date);

• Information related to your travel profile (e.g., arrival and departure time, nationality, passport and visa data, accommodation and travel preferences, travel itinerary, tour group, language preference, travel agent/company);

• Your resort stays or interactions, and purchases of goods and services during your resort visits, (e.g., restaurant visits, preferred room types, child care services, spa services, concierge requests);

• Your membership to Vertu Club or invitations to visit Vertu Club as a guest. The membership information consists of contact information, financial information, member photographs, images and audio data via security camera, activity and dietary preferences);

• Purchase and delivery of gift cards and personal messages in relation to gift cards sold through Vertu’s website and that can be used to book resort stays;

• Inquiries about private travel (Vertu private jet and yacht) or residential sales and preferences in relation to residential sales;

• Social media and WhatsApp Messenger account ID, profile photo and other data publicly available, or data made available by linking your social media;

• IP address (we may also derive your approximate location from your IP address);

• Images, video and audio data via security cameras (CCTV) located in public areas of our properties, such as hallways and lobbies;

We may also collect the following information (either based on our legitimate interests or with your consent to the extent required by applicable law):

• Personal data about family members and companions (e.g., names and ages of children) to help us make your stay with us as comfortable as possible (e.g., we can proactively plan for additional accommodations such as a crib or extra bed for children accompanying you); 

• Important dates, such as birthdays, anniversaries and special occasions to make the stay with us more enjoyable and allow us to provide you with a birthday or anniversary gift;

• Guest preferences and personalized data to make more enjoyable your stay and experiences with us, such as likes and dislikes about our services that you may tell us about so that we can improve our services and special health accommodations (e.g., food allergies, dietary requirements, mobility requirements) or information related to your general health and physical characteristics, and your skincare and wellness concerns (e.g., skin type, hair type, skin sensitivity, contraindications, beauty concerns, preference for nourishing or purifying skincare products);

• Information collected through guest surveys relating to your satisfaction

• Inquiries via WhatsApp Messenger;

• Information about visits to Vertu properties by journalists, PR agency staff, consultants and business partners.

We and our service providers collect Personal Data in a variety of ways, including:

• Within the Vertu Group We disclose Personal Data to other companies within the Vertu Group and Vertu Essentials for the purposes described in this Privacy Notice, such as making the Services unique to you, communicating with you, supporting the Vertu Club, and to accomplish our business purposes. 

• Through the Services.  We collect Personal Data through the Services, for example, when you make a reservation, communicate with us, or otherwise connect with us or post to social media pages, or sign up for a newsletter or participate in a survey, or promotional offer. 

• When you Visit Us. We collect Personal Data when you visit our properties or use on-property services and outlets, such as restaurants, concierge services, health and fitness facilities, child care services, spas, and local tours. 

• Via our Customer Support. We collect Personal Data when you make a reservation over the phone, communicate with us by email, fax or via WhatsApp or contact customer service known as "Shared Services". These communications may be recorded, for example, for purposes of quality assurance and training.

• When you apply to become a member of Vertu Club.

• When you inquire about Vertu Residences and in connection with sales or professional management of Vertu residences.

• From Resort Owners. We collect Personal Data from owners of Vertu Group branded properties that we manage. 

• From Vertu Partners. We collect Personal Data from companies with whom we partner to provide you with services or offers (“Vertu Partners”). Examples of Vertu Partners include travel and tour partners, and travel booking platforms. Vertu Partners are independent from the Vertu Group. 

• From Other Sources.  We receive your Personal Data from other sources, for example: publicly available databases and joint marketing partners, when they share the information with us or from individuals who have sent you a gift card.

We collect Personal Data to provide the Services to you. If you do not provide the information requested, we may not be able to provide certain Services. If you disclose any Personal Data relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Notice.

Cookies & Similar Technologies

When you use the Online Services, we also collect data typically collected through websites, such as browser and device information, application usage data, information collected through cookies, pixel tags and other similar technologies, and IP addresses. For more detail please see our Cookie Policy.

We and our service providers use Personal Data for the following purposes: 

• Providing the functionality of the Services and fulfilling your requests.

  • To process and facilitate bookings, reservations and payments, including verifying your identity, taking payments and communicating with you.

  •  To respond to your requests and queries during your stay at Vertu properties.

  • To run our e-billing program. When you provide an email address in making a reservation, we use that email address to send you a copy of your bill. If you make a reservation for another person using your email address, that person's bill will be emailed to you, as well. 

  • To process and deliver your order of our fashion and skincare products.

  • To process and deliver gift cards.

  • To manage your Vertu Club membership, such as arranging access to your account, assessing and providing you with related benefits, special promotions, or customer service, and managing your choices about how you wish to earn, track and use your points.

  • To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, compliments or complaints, or when you request a quote for or other information about our Services.

  • To complete your transactions, process returns and exchanges, verify your information, and provide you with related benefits, special promotions, or customer service.

  • To prepare the sales agreement and of Vertu residences and agreements in relation to professional property management services.

  • To send administrative information to you, such as changes to our terms, conditions, and policies. 

We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation. 

• Providing you with our newsletter and/or other marketing materials and facilitating social sharing.

  • To send you marketing related emails, with information about our services, new products and other news about our company. 

  • To conduct surveys about your experience during resort visits.

  • To facilitate social sharing functionality that you choose to use.

We will engage in this activity with your consent or where we have a legitimate interest.

• Enabling us to recognize or identify Vertu Club members when entering Vertu New York premises and for sales of properties

We will engage in this activity with the consent of Vertu Club members.

• In connection with Vertu properties Sales

  • To conduct anti-money laundering checks and sanctions screening and obtain background reports in relation to sales of Vertu residences.

We will engage in this activity to comply with a legal obligation or with your consent.

• Analyzing Personal Data for business reporting and providing personalized services.

  • To analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our Services. To better understand your interests and preferences, so that we can personalize our interactions with you and provide you with highly-individualized services, information and/or offers tailored to your interests during your stay at Vertu properties, and when you contact our customer support or use the Online Services.

  • To better understand your preferences so that we can deliver content via our Services that we believe will be relevant and interesting to you.

  • To conduct surveys and business intelligence activities to offer and improve the products and services and investigate any complaints received from clients or from others, about our website or our products or services.

We will provide personalized services based on our legitimate interests, and with your consent to the extent required by applicable law. 

• Anonymizing Personal Data.

We may anonymize Personal Data so that it will no longer be considered Personal Data. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual. 

We have legitimate interest to anonymize Personal Data. 

• Accomplishing our business purposes.

  • For data analysis, for example, to improve the efficiency of our Services; 

  • For audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements; 

  • For fraud prevention and fraud security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft; 

  • For developing new products and services; 

  • For enhancing, improving, repairing, maintaining, or modifying our current products and services, as well as undertaking quality and safety assurance measures; 

  • For identifying usage trends, for example, understanding which parts of our Services are of most interest to users; 

  • For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users; and 

  • For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests.  

We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or based on our legitimate interest.

We disclose Personal Data to: 

• Vertu affiliates for the purposes described in this Privacy Notice. 

• Owners of Vertu Group branded properties for the purposes described in this Privacy Notice, such as providing and tailoring the Services. 

• Vertu Partners who provide goods, services and offers that enhance your experience at Vertu properties or that we believe will be of interest to you. For example, sharing your Personal Data with Vertu Partners enables our spa, restaurant, fitness facility, concierge and other external service providers at Vertu properties to provide you with personalized services. This sharing also enables us to provide you with a convenient, single source for purchasing packages that include travel-related services, such as airline tickets, rental cars, tours, and vacation packages. 

• Our third party service providers, to facilitate services they provide to us. These can include providers of services such as Vertu Club digital card, website hosting, website booking facilitation, data analysis, payment processing, order fulfillment, return authorization, fraud prevention, information technology and related infrastructure provision, customer service or related benefits (including special promotions), email delivery, auditing, and other services. 

• Third parties, to permit them to send you marketing communications, consistent with your choices.

We also use and disclose your Personal Data as necessary or appropriate, in particular when we have a legal obligation or legitimate interest to do so:

• To comply with applicable law and regulations.

  • This may include laws outside your country of residence. 

• To cooperate with public and government authorities.

  • To respond to a request or to provide information we believe is necessary or appropriate.

  • These can include authorities outside your country of residence.

• To cooperate with law enforcement.

  • For example, when we respond to law enforcement requests and orders or provide information we believe is important.

• For other legal reasons.

  • To enforce our terms and conditions; and

  • To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others. 

• In connection with a sale or business transaction.

  • We have a legitimate interest in disclosing or transferring your Personal Data to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings). 

By using the Services, you may elect to disclose Personal Data:

• On social media platforms, chat, and other services to which you are able to post information and content (including, without limitation, our Social Media Pages).  Please note that any information you post or disclose through these services will become public and may be available to other users and the general public. 

• Through your social sharing activity.  When you connect your Services account to your social media account, you will share information with your friends associated with your social media account, with other users, and with your social media account provider. By doing so, you authorize us to facilitate this sharing of information, and you understand that the use of shared information will be governed by the social media provider’s privacy policy. 

This Privacy Notice does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates. 

In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Instagram, Google Ads, Yahoo, Baidu, RED, Weibo. Line, Tripadvisor, Trivago, Yandex, Apple, Microsoft, The Hotels Network or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Data you disclose to other organizations through or in connection with our Social Media Pages.

We use third-party advertising companies (such as Meta, Google, Yahoo, Baidu, RED, Weibo. Line, Tripadvisor, Trivago, Yandex,) to serve advertisements regarding goods and services that may be of interest to you when you access and use the Services and other websites or online services.
You may receive advertisements based on information relating to your access to and use of the Services and other websites or online services on any of your devices, as well as on information received from third parties.  These companies place or recognize a unique cookie on your browser (including through the use of pixel tags).  They also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop.  If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device on which you are accessing this Privacy Notice, please visit http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/#/. 

We give you choices regarding our use and disclosure of your Personal Data for marketing purposes.  You may opt out from:  

• Receiving marketing-related emails from us.  If you no longer want to receive marketing related emails from us on a going-forward basis, you may opt out by sending an email to dpo@vertugroup.com or by using the unsubscribed link at the bottom of each marketing email.

• Our sharing of your Personal Data with affiliates for their direct marketing purposes.  If you would prefer that we discontinue sharing your Personal Data on a going-forward basis with our affiliates for their direct marketing purposes, you may opt out of this sharing by sending an email to dpo@vertugroup.com or by using the unsubscribed link at the bottom of each marketing email.

We will try to comply with your request(s) as soon as reasonably practicable.  Please note that if you opt out of receiving marketing related emails from us, we may still send you important administrative messages, from which you cannot opt out.

If you would like to request to access, correct, update, suppress, restrict, or delete Personal Data, object to or opt out of the processing of Personal Data, or if you would like to request to receive a copy of your Personal Data for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), you may contact us in accordance with the “Contacting Us” section below.  We will respond to your request consistent with applicable law.

 
In your request, please make clear what Personal Data you would like to have changed or whether you would like to have your Personal Data suppressed from our database.  For your protection, we may only implement requests with respect to the Personal Data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request.  We will try to comply with your request as soon as reasonably practicable. 
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Data provided until after the completion of such purchase or promotion).  

Where provided by applicable law, you may also lodge a complaint with the UK data protection authority here or with an EU/EEA data protection authority for your country or region where you have your habitual residence or place of work or where an alleged infringement of applicable data protection law occurs. A list of data protection authorities is available here.

We retain Personal Data for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.  

The criteria used to determine our retention periods include:  

• The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services); 

• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or 

• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).  

We seek to use reasonable organizational, technical and administrative measures to protect Personal Data within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section, below.

Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Services or otherwise to us.

The Services are not directed to individuals under the age of sixteen (16), and we do not knowingly collect Personal Data directly from individuals under 16.  

Your Personal Data may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. 

ADDITIONAL INFORMATION REGARDING THE EEA/UK: Some non-EEA/UK countries are recognized by the European Commission and UK government, respectively, as providing an adequate level of data protection according to EEA/UK standards (the full list of these countries for the EEA is available here and for the UK is available here). For transfers from the EEA and the UK to countries not considered adequate by the European Commission and the UK government, respectively, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission and UK government to protect your Personal Data. You may obtain a copy of these measures by contacting us in accordance with the “Contacting Us” section below.

The “LAST UPDATED” legend at the top of this Privacy Notice indicates when this Privacy Notice was last revised. Any changes will become effective when we post the revised Privacy Notice on the Services.

Vertu GmbH and its affiliates in the Vertu Group are responsible (data controllers) for the Personal Data we hold about you. The Vertu Group is also an independent controller in relation to our resort owners, who have a limited right to use the Personal Data we collect. As the hotel you are booked to stay in may not be owned by the Vertu Group, we disclose Data to owners of Vertu Group branded properties for the purposes described in this Privacy Notice. Owners have a limited right to use certain Personal Data for their own purposes and therefore qualify as independent data controllers in order to comply with their own legal obligations (including maintaining books & records and other compliance obligation). 

Vertu Group GmbH is the controller of marketing database and conducts all marketing activities relating to Vertu Hotels and Resorts, Vertu Club and Vertu Residences.

Vertu Group’s address is Vertu GmbH, Gubelstrasse 24, 6300 Zug, Switzerland. 

Vertu’s European Representative is VERTU - LUXURY COMMUNICATION EURL, a company established in the France, with offices located in France, address 10 Place Vendôme, 75001 Paris.  

You may always contact us at dpo@vertugroup.com or our EU Representative at eurodpo@vertugroup.com with your questions or concerns regarding this Privacy notice or in general about our processing of your Personal Data.