Introduction

Beckons (including Luxury Lodges US Holdings, LLC and our affiliated lodge operating entities) (“we”, “us”, “our”) recognizes that your privacy is important and is committed to protecting your personal information.

This Privacy Policy explains how we collect, use, disclose and protect personal information throughout the full guest lifecycle, including when you:

• visit our websites;
• make enquiries or reservations;
• stay at one of our lodges;
• interact with guest services; or
• otherwise engage with us.

Beckons is the data controller of personal information collected through our websites and central booking systems. In certain circumstances, affiliated lodge operating entities may also process personal information in connection with local operational activities.

We process personal information in accordance with applicable privacy and data protection laws in the jurisdictions in which we operate. Where the European Union General Data Protection Regulation (GDPR) applies, we process personal information on lawful bases including performance of a contract, compliance with legal obligations, legitimate interests, and consent where required.

Types of Information Collected

We may collect and store personal information about you, such as:

• biographical details (including your name and address);
• contact details (including your email address and phone number);
• guest details;
• room and stay preferences;
• reservation and itinerary details;
• payment card information and billing details;
• identity details (e.g., passport or driver’s license);
• images captured by closed circuit television in public areas of our premises;
• dietary and other personal preferences;
• employment or recruitment-related information (if applicable);
• website usage data, including IP address, browser details and device information;
• any other information relevant to providing you with the services you are seeking, or someone else you know is seeking; and
• any other information we are required or authorized by law to collect.

Sensitive Information

Under certain circumstances, we may also collect sensitive information about you.
Sensitive information includes any information or opinion about your racial or ethnic origin, political opinions, political association, religious or philosophical beliefs, membership of a trade union or other professional body, sexual preferences, criminal record, or health information.

Examples of sensitive information that may be collected include:

• health information (e.g., in the context of accessibility requirements or allergies); and
• incident information (e.g., in responding to medical or safety incidents).

Where required by law, we will obtain your consent before collecting sensitive information unless an applicable legal exception applies.

Purposes of Collection

We collect and use personal information for one or more of the following primary purposes:

• providing information and services to you;
• managing reservations, stays and guest services (including sales, payments, communications and customer service);
• personalizing and enhancing your guest experience;
• undertaking activities required or authorized by law or contract, including enforcing agreements and managing claims or disputes;
• responding to and complying with requests and legal demands from regulators or other authorities;
• providing marketing communications where permitted by law;
• facilitating internal business operations, analytics and service improvement;
• supporting security, safety and fraud prevention processes; and
• managing corporate transactions, including mergers, acquisitions, restructures or transfers of business.

Where GDPR applies, we process personal information on lawful bases including performance of a contract, compliance with legal obligations, legitimate interests, and consent where required.

Methods of Collection

Personal information will generally be collected directly from you through our websites, booking platforms, email communications, telephone interactions or in person during your stay.

We may also collect personal information indirectly from travel agents, booking partners, affiliated entities or publicly available sources where permitted by law.

Disclosure of Personal Information

We may disclose personal information to:

• affiliated Beckons entities and lodge operating entities;
• service providers who assist us in operating our business (including booking systems, payment processors, IT providers, marketing platforms and professional advisers);
• third parties who provide services that you have requested and that we arrange on your behalf;
• regulators, courts or government authorities where required or authorized by law; and
• parties involved in corporate transactions, including mergers, acquisitions or asset transfers.

We do not sell personal information.

Cross-Border Transfers

As a global hospitality group, we may transfer or store personal information in countries outside the country in which it was collected, including where our affiliated entities or service providers operate.

Where personal information is transferred internationally, we take reasonable steps to ensure it is protected in accordance with applicable data protection laws. Where required, this may include the use of appropriate contractual safeguards or other lawful transfer mechanisms.

Internet Users and Cookies

If you access our websites, we may collect information about your session in the form of IP address, browser details, device identifiers and usage data.

Our websites use cookies and similar technologies to:

• enable website functionality;
• enhance user experience;
• analyze usage and performance; and
• support marketing activities where permitted.

You may adjust your browser settings to manage or disable cookies. However, doing so may impact certain features or functionality of our websites.

Server logs and technical records may be retained as reasonably necessary to maintain system security and integrity.

Storage and Retention of Personal Information

We will store your personal information for as long as reasonably necessary for the purposes for which it was collected.

We actively review the personal information we store and will securely delete or de-identify personal information once it is no longer required for any purpose permitted under applicable law.

Security

We take reasonable administrative, technical and physical measures to protect personal information from misuse, interference, loss, unauthorized access, modification or disclosure.

Your Rights

Depending on your location and applicable law, you may have the right to:

• request access to the personal information we hold about you;
• request correction of inaccurate, incomplete or outdated personal information;
• request deletion of personal information in certain circumstances;
• request restriction of processing;
• object to certain processing activities;
• request data portability (where applicable); and
• withdraw consent where processing is based on consent.

We will respond to requests within the timeframe required by applicable law and may require verification of your identity.

Feedback, Queries and Complaints

If you have any feedback, queries or complaints regarding our handling of personal information, please contact:

Privacy Officer – Beckons
100 St. Paul Street, Suite 800
Denver, CO 80206
United States
privacy@beckons.com

If you are not satisfied with our response, you may contact the applicable privacy regulator in the jurisdiction where the relevant lodge operates or where you reside, including:

• Australia: Office of the Australian Information Commissioner (OAIC)
• New Zealand: Office of the Privacy Commissioner
• Canada: Office of the Privacy Commissioner of Canada or relevant provincial regulator
• European Union: Relevant Data Protection Authority in your member state

Updates

We may update this Privacy Policy from time to time. The updated version will be published on our websites with a revised “Last updated” date.