This Privacy Policy (the “Policy”) explains how Scotsman Hotel Inc., its affiliates and subsidiaries (“The Scotsman”, “we”, “our”, or “us”) collect, use and disclose the personal information you may provide while using our website: thescotsmanhotel.ca (the “Website”), or in any other communication or interaction you may have with us (the “Services). Any personal information you provide will be treated with care, and will not be collected, used or disclosed except as provided for by this Policy or as otherwise permitted by law. This Policy may be supplemented by specific policies, procedures, and practices.
ACCEPTANCE OF POLICY
By accessing and using the Website or Services, you accept the Policy and consent to its terms and any specific terms as otherwise described to you at the time of collection of your personal information. If you do not agree to be bound by these terms and conditions, please do not access or use the features of this Website or our Services. We may in our sole discretion, at any time and without any notice to you, revise or amend the terms and conditions of the Policy by posting an amended Policy on the Website. By continuing to access and use the Website or Services, you agree to the terms of the then current Policy, as amended.
The Scotsman may use your personal information to inform you of current and/or new promotions or services or other developments that The Scotsman believes will be of interest to you in accordance with applicable laws. Such communications may be made by way of telephone, text message, direct messaging, e-mail or regular mail. You provide your consent to The Scotsman contacting you in this manner when you use The Scotsman’s products or services. You may opt-out of receiving such communications by contacting The Scotsman at the address below.
WHAT INFORMATION IS COLLECTED?
Non-personal information
We collect certain non-personal information which is recorded by the standard operation of our Internet servers on an anonymous basis, such as the operating system you are using, the sections of the Website you visit, the Website pages read and images viewed, and any content you post to or download from the Website. This non-identifiable information is used on an aggregate basis and in a non-personally identifiable form, including:
- for Website and system administration purposes
- to improve the Website
- to conduct internal reviews of the number of visitors to the Website
- to help us better understand visitors’ use of our Website
- to fulfill prizes
- to respond to specific requests from our visitors
- to protect the security or integrity of our Website when necessary
tracking information
We may use non-personal information to create aggregate tracking information reports regarding Website traffic patterns and uses, and then provide those reports to advertisers and others. None of the tracking information in the reports can be connected to the identities or other personal information of individual users. We may link tracking information with personal information provided by the Website users; once such a link is made, all of the linked information is treated as personal information and will be used and disclosed only in accordance with the Policy.
Google analytics
Please note that we may use Google Analytics. There is more information about how Google collects, uses, and processes data at http://www.google.com/policies/privacy/partners/.
Personal information
The Scotsman only collects personal information about you that is necessary for the purposes of establishing, managing and maintaining our relationship with you. For example, you provide to us your e-mail address and other personally identifiable information, such as first and last name, birthdate, postal address (shipping and billing) and telephone number when you submit such information via registration on the Website, in person or by telephone, by providing us feedback in any manner, in connection with registration for contests, submission or suggestions for contests, or participation in any other available on-line, or other interactive activities. We also collect your IP address, which we either anonymize, so as it is not personal information, or treat as personal information under the Policy. You can choose not to provide such information, but then you may not be able to take advantage of many of our Website features or other Services. Reservation details, guest names, addresses, birth dates, proof of identity, billings/invoices, and meal/alcohol purchases are also collected when you attend our hotel or otherwise use our Services.
Generally, we will obtain your personal information directly from you. However, we may also collect personal information about you from outside sources with your express or implied consent or without your consent if the law so authorizes, notably when the collection from a third person is necessary to ensure the accuracy of the information (e.g. to confirm your identity, to prevent errors or fraud, etc.), if the third person is authorized to communicate such information.
Use of your personal information
We may use your personal information to contact and correspond with you, to respond to your communications, fulfill your reservations and orders, and to facilitate and enhance your use of the Website. We may also use your personal information in: (i) establishing, maintaining and/or fulfilling relationships with our business partners, third-party vendors of products and/or services, as well as our corporate and business customers, if it is necessary for them to assist The Scotsman of the purposes of establishing, managing and maintaining our relationship with you; (ii) for conducting operating, administering and otherwise managing our business, to satisfy legal, regulatory, security, audit, financial and processing requirements, or (iii) as otherwise permitted or required by law. We may develop a confidential user profile for you, which will be used to facilitate your use of the Website or Services. In certain instances, we may use your personal information to obtain parental consent from visitors under 18 years of age, and where necessary, to provide any necessary notices to our visitors or their parent or guardians. We may keep a record of all communications with you.
The Scotsman may also use your personal information to compile statistics. However, these statistics will not allow you to be identified. Your personal information shall not be used for purposes other than those described above except with your consent or as required or authorized by law.
DISCLOSURE OF YOUR PERSONAL INFORMATION
We do not sell, transfer or otherwise disclose your personal information without your consent except in the cases and under the conditions described hereinafter:
- Disclosure to Affiliates and Others. Access within The Scotsman does not require your consent but is strictly limited to the persons for whom such information is necessary for the performance of their functions and duties. We may also share personal information within the White Owl Family Office Group Limited group of companies without your consent, if it is necessary for them to assist the Scotsman for the purposes of establishing, managing and maintaining our relationship with you. This group includes Scotsman Hotel Inc. our subsidiaries and our affiliates. All recipients of this information will be required to comply with the Policy.
- Disclosure to outside third-party services providers. The Scotsman may also share your personal information, without your consent, with outside agents, mandataries, consultants, data processors, service providers and other parties who require such information in connection with The Scotsman’s activities or to assist The Scotsman with administering Services or our business relationship (fulfilling orders, assisting with promotions, providing technical assistance for the website, etc.). Such agents, mandataries, consultants, data processors, service providers and other parties will be required to use your personal information conveyed by The Scotsman exclusively to provide specific services and to keep it confidential in accordance with this policy.
- Disclosure of Business Transfers. We may be involved in the sale or transfer of some or all of our businesses. As part of that sale or transfer transaction, we may disclose your personal information to the acquiring organization, but will require the acquiring organization to agree to protect the privacy of your personal information in a manner that is consistent with the Policy.
- Law Enforcement and Legal Disclosure. We may disclose your personal information to meet legal, audit, regulatory, insurance, security or related requirements. Such disclosure includes a government institution that has asserted its lawful authority to obtain the information or where we have reasonable grounds to believe the information could be useful in the investigation of unlawful activity, or to comply with a subpoena or warrant or an order made by a court, person or body with jurisdiction to compel the production of information, or to comply with court rules regarding the production of records and information, or to our legal counsel, or to protect our respective rights and property.
THIRD PARTY WEBSITES
You may be directed to our Website or Services, or our Website may provide links or references to websites, operated by third parties. We do not control third party websites. When you utilize third-party booking service, marketing, or other websites to access our Website or Services, or when you click on links and/or ad banners on our Website that take you to third party websites, you will be subject to the privacy policies and terms of use of those third-party websites and your use of these websites and their products and services is at your own risk. We have no responsibility or liability for or control over those websites or their collection, use and disclosure of your personal information, even where such websites may lead to our Website or the provision of Services. In visiting any third party websites, whether linked to our Website or otherwise, you do so at your own risk and you assume all responsibility in that regard. We make no representations or warranties regarding, and do not endorse, any third party website or any content in such website. We encourage you to review the privacy policies of each website visited before using those websites or disclosing any Personal Information to third parties.
SAFEGUARDING YOUR INFORMATION
The Scotsman takes all reasonable precautions to protect your personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, regardless of the format in which the information is held. These security safeguards include physical measures, organizational measures and technological measures that are reasonable given the sensitivity of the information, the purposes for which it is to be used, the quantity and distribution of the information and the medium on which it is stored. Such measures may necessarily evolve over time as the availability and effectiveness of methods vary, Nevertheless, given the nature of the Internet and human factors, security and privacy risks cannot be entirely eliminated and you should be aware of this before you send us an email message or other communication through the Website or use our Services. The Scotsman also takes the necessary measures to ensure that all its managers and employees are trained on the contents of this Policy and understand that they are required to conform to it at all times.
In addition, while we routinely assess and monitor the security of our electronic systems and adopt safeguards intended to protect and prevent unauthorized access to and use of our electronic systems, we make no representation or warranty with respect to the security of electronic communications, the Website, or our systems used in providing Services.
The protection of personal information is of paramount concern to The Scotsman, and we are prepared to take appropriate and timely steps in the event of any incidents involving personal information in accordance with applicable privacy laws.
ACCESSING YOUR PERSONAL INFORMATION AND CONTACTING US
You may access your Personal Information held by the Scotsman to the extent required by law. Individuals may write to or email our Privacy Officer at the address below to request access to Personal Information held about them. Upon written request and authentication of identity, we will comply with our legal obligations to provide you with your Personal Information under our control, information about the ways in which that Personal Information is being or was used, and a description of the individuals and organizations to whom that Personal Information may have been disclosed.
We may charge a reasonable fee for providing Personal Information in response to an access request and will provide an estimate of any such fee upon receiving an access request. We may require a deposit for all or part of the fee. We will make the Personal Information available within 30 days or provide written notice where additional time is required to fulfill the access request.
In some situations, we may not be able to provide access to certain Personal Information. For example, access would be denied if disclosure would reveal Personal Information about another individual, or disclosure of the Personal Information would reveal confidential commercial information that, if disclosed, could harm the Scotsman or any of its former, current or potential customers. There are also circumstances where the Scotsman may be prevented by Canadian federal or Ontario law from providing access to certain Personal Information.
If a request for access to Personal Information is denied, the Scotsman will provide an explanation of the reasons for such refusal as required by applicable laws.
Privacy Officer
For further information about The Scotsman’s privacy practices, or to exercise any other rights outlined in this Policy, please contact The Scotsman’s designated Privacy Officer at the following address:
ATTN: Privacy Officer
Scotsman Hotel Inc.
95 Johnson St,
Niagara-on-the-Lake, ON L0S 1J0
info@thescotsmanhotel.com
With a copy to:
legal@whiteowlgroup.ca