Hard Rock Hotel DalianPrivacy Policy

Last Updated: November 5, 2021
Effective: November 5, 2021

WE RESPECT THE PRIVACY OF EVERY INDIVIDUAL WHO USES OUR SERVICES.
This Privacy Policy explains how we, our website (https://www.hardrockhotels.com/dalian, "Website") and/or our WeChat Mini-program ("Mini-program") collect and otherwise process the information relates to an identified or identifiable natural person (excluding anonymized information) ("Personal Information"), including Reservation Information as defined below.  Please note that this Privacy Policy does not apply to Personal Information collected in our Rewards Program or Rewards App, which are governed by the policy at https://members.hardrock.com/privacy-policy (the “Rewards Privacy Policy”) which may be updated when it applies to individuals resident in China, or to personal information collected on our https://www.HardRock.com website or apps.  You may choose to submit Personal Information (such as your name, IDENTIFICATION CARD NUMBER, ADDRESS, e-mail address, birthdate, and telephone number) to us at the premises of Hard Rock Hotel Dalian ("Hotel") or through the Website or the Mini-program.  We collect, store, use, process, transfer, provide, delete or otherwise process Personal Information for providing accommodation and other services to you at the Hotel and other business purposes set out in this Privacy Policy only unless otherwise permitted by applicable law.  We will not share this information in ways different from what is disclosed in this Privacy Policy.  If you have any questions about this Privacy Policy, the Website, or the Mini-program, please contact us at dataprotection@hrh-dalian.com.

WHO IS COLLECTING YOUR PERSONAL INFORMATION
Dalian Luneng Real Estate Development Co., Ltd ("Hard Rock", “we”, “us” or “our”) is the personal information processor under this Privacy Policy.  This Privacy Policy applies only to the personal information collected at the premises of the Hotel and via the Website and the Mini-program, and not to the third party booking engines described below or websites for the independently owned and managed Hard Rock hotels that receive job posting information.

LINKS

We may provide you links to other sites whose privacy policies may differ from those of Hard Rock, which we recommend you carefully review and consider. We cannot be responsible for the privacy policies and practices of other websites even if you access those websites using links provided by us, such as hotels that are not owned or managed by Hard Rock, but are owned by franchisees, which are separate and independent entities from Hard Rock.

WHAT PERSONAL INFORMATION DO WE COLLECT
We will collect your name, IDENTIFICATION CARD NUMBER (or other IDENTIFICATION DOCUMENTS, such as PASSPORT) and status, telephone number, check-in and check-out time.  Such Personal Information is necessary for us to provide accommodation services to you.  When you make a reservation, you may be asked to supply additional Personal Information, including email address, birthdate, employer or company name, ADDRESS, designation, city and region, loyalty number, and CREDIT CARD, DEBIT CARD OR OTHER FORM OF PAYMENT INFORMATION (collectively with the necessary information above, “Reservation Information”) and other Personal Information as set out in this Privacy Policy depending upon the way you choose to make the payment and/or for our supplementary and extended services.

We collect Personal Information in several ways: (1) indirectly, i.e., certain information about you, including domain name, IP address, browser type and page views, mobile device ID and type, and GEOLOCATION (as applicable) which is collected through our Website and Mini-program's technology to provide certain functionality to you, to remember you when you return, to customize the Website and the Mini-program to your preferences and manage content, and compile statistics about usage of the Website and the Mini-program; and (2) directly, when (a) you voluntarily submit Personal Information, including first and last names, ADDRESSES, email address(es), phone numbers, marital status, family information, and types of business information, in connection with requests for proposals for weddings, meetings and other special events; along with birthdate, number of children and their AGES, social network and ‘handle’ data, preference information, or survey answers/opinions in connection with other various offers, marketing and promotional activities, contests/sweepstakes, or surveys; (b) when you register to become a user of the Website or the Mini-program, we will collect the password and security question/answer; and (c) directly, when you make a reservation at the Hotel onsite, on the Website or the Mini-program, or through one or more independently operated booking engines (see “Reservation System” below for more information on how this system works).  When we collect this type of Personal Information, we will notify you as to why we are asking for the Personal Information and how this Personal Information will be used either in this Privacy Policy or separately at the point at which the Personal Information is collected if not described in this Privacy Policy.

RESERVATION SYSTEM
The Reservation Information might be collected and processed by one of several online booking engines (“Booking Engines”) that are used by us.  

These Booking Engines will provide the Reservation Information to us to complete your reservation and to provide you services.  Some of the Reservation Information may also be provided to us to verify if a visit occurred and for purposes of tracking loyalty rewards under the Hard Rock Rewards Program.

The Booking Engines are contracted to collect and provide the Reservation Information to us for purposes of making and managing your reservations at the Hotel.  However, they are separately owned and operated from us, and therefore this Privacy Policy does not pertain to the policies and practices of such Booking Engines.  Please consult the privacy policies of relevant Booking Engines regarding their policies and practices with respect to the Personal Information they collect and process in providing these reservation services.

WE MAKE NO REPRESENTATION AND WARRANTIES REGARDING SUCH BOOKING ENGINES, ANY THIRD PARTY ENGAGED BY THE BOOKING ENGINES OR THEIR INFORMATION SECURITY OR PRIVACY PRACTICES.  PLEASE NOTE THAT WE DISCLAIM ANY AND ALL RESPONSIBILITY OR LIABILITY RELATING TO THE USE OF YOUR PERSONAL INFORMATION (INCLUDING RESERVATION INFORMATION) BY THE BOOKING ENGINES AND ANY THIRD PARTY ENGAGED BY THE BOOKING ENGINES.

RIGHT NOT TO PROVIDE INFORMATION
You have the right not to provide Personal Information.  However, if you elect not to provide the necessary Personal Information as described above, you may not be able to utilize the basic accommodation service.  If you elect not to provide part or all of the additional information as described, you may not be able to utilize the supplementary services, but it will not affect the basic accommodation service.

SENSITIVE INFORMATION
THE PERSONAL INFORMATION WE COLLECT AND PROCESS MAY CONTAIN SENSITIVE PERSONAL INFORMATION.  THE INFORMATION WE COLLECT AND WHICH MIGHT BE DEEMED AS SENSITIVE PERSONAL INFORMATION IS IN UPPERCASE IN THIS PRIVACY POLICY FOR YOUR SPECIAL ATTENTION, INCLUDING YOUR IDENTIFICATION CARD NUMBER, ADDRESSES, PAYMENT INFORMATION, GEOLOCATION, THE PERSONAL INFORMATION OF YOUR CHILDREN UNDER 14 YEARS OLD, ETC.  In each case, we will make sure that the processing of your sensitive Personal Information is for specific purposes as described in this Privacy Policy and is necessary; we will take strict security measures when processing the sensitive Personal Information and such processing will be conducted in a manner having the least impact on your personal rights and interests.
YOU EXPRESSLY AND VOLUNTARILY CONSENT TO THE PROCESSING BY US OF YOUR SENSITIVE PERSONAL INFORMATION FOR THE PURPOSES AND IN THE MANNER DESCRIBED IN THIS PRIVACY POLICY.

COOKIES
Some information that we collect about you is collected passively through the use of "cookies."  Cookies are small files of information, which save and retrieve information about your visit to the Website — for example, how you entered and navigated our Website, and what information was of interest to you.  We use this information to remember you when you return and to customize our Website to your preferences.  We also allow certain third party advertisers and partners to collect Personal Information about your use of the Website through first and third-party cookies in order to serve adverts to you.  They may also analyze this Personal Information in order to serve adverts to you on other third-party websites. You may set your Web browser to notify you when you receive a cookie or to not accept certain cookies.  However, in some cases, you may find that some parts of the Website will not function properly if cookies are refused.  

CLEAR GIFS, PIXEL TAGS AND OTHER TECHNOLOGIES
Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies.  In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages.  We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Website to, among other things, track the activities of Website visitors, help us manage content, and compile statistics about Website usage.  We and our third party service providers also use clear GIFs in HTML e-mails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.

THIRD PARTY ANALYTICS/TRACKING
We use automated devices and applications, such as Google Analytics, to evaluate the usage of our Website.  We also may use other analytic means to evaluate our services.  We use these tools to help us improve our services, performance and user experiences.  These entities may use cookies and other tracking technologies to perform their services.

AUTOMATED DECISION MAKING AND PROFILING
We do not use any automated decision making in our business processes.

PERSONAL INFORMATION RIGHTS
You have choices about our collection, storage, use, processing, transmission, provision, publication and deletion of your Personal Information, including:

Deletion: You can request that we erase or delete all or some of your Personal Information (e.g., it is no longer necessary to provide services to you).

Change or Correct: You can request that we change or correct your Personal Information.  Among others, if you created an account with us, you can review and edit your Personal Information by logging onto the Website or the Mini-program and visiting your account.  Please note that personal profile information supplied by you on the Website or the Mini-program can be accessed by you online at any time and no charge.

Object to or Restrict Use: You can request that we stop using some or all of your Personal Information or restrict our use of your Personal Information.

Access and/or Take: You can request a copy of your Personal Information.
Right to Portability: You can request that we transfer your Personal Information to a personal information processor designated by you and we will enable such transfer, provided that this satisfies the conditions imposed by the national cyberspace authority.
Marketing: If you no longer wish to receive our newsletter or promotional materials, you may opt-out of receiving these communications by clicking the unsubscribe link at the bottom of the email.

Withdrawing Consent: If we have collected or processed your Personal Information with your consent, you may withdraw your consent at any time.  Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your Personal Information based on other lawful processing grounds.
Explanation: You can request us to explain our Personal Information processing rules.

If you request access, correction, amendment or deletion of your Personal Information and you have more than one account with us, you will need to instruct us on each account separately.  Reasonable access to Personal Information will generally be provided within fifteen (15) working days at no cost to you, subject to limited exceptions prescribed by law or excessive requests.

For your protection, we may need to verify your identity before fulfilling your request.  Please note that we may need to retain certain Personal Information for recordkeeping purposes or to complete transactions that occurred prior to your request.  We will also retain your Personal Information if reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, to the extent permissible by the applicable law.

We aim to keep the Personal Information about you as accurate as possible.  If you would like to access, update, review or change the details you have supplied us with or exercise any of your Personal Information rights that you are entitled to under the applicable law, please contact us as set out below in "HOW TO ACCESS AND UPDATE USER INFORMATION" and "HOW TO CONTACT US" sections.

SUBSCRIBERS/ORDERS
In order to use and participate in certain programs or services offered by us, you may be asked to first complete a registration form.  In order to use or participate in such programs and services, we will need to collect certain Personal Information about you, such as your name, email address and contact details, and, if applicable, CREDIT CARD PAYMENT INFORMATION.  This information is used to communicate with you about specific services, offers, benefits and features for which you have expressed interest or registered.  For some services, you may be asked to provide a password and user identification.  This information is collected to confirm eligibility for use of the online services and to establish the identity of the authorized user.  You are responsible for maintaining the confidentiality of that password and user identification.

SURVEYS & CONTESTS
From time to time, we may request Personal Information from you via surveys or contests.  Participation in these surveys or contests is completely voluntary.  Requested Personal Information may include your contact information, data of birth, marital status, number of children and their AGES, and your opinion/answers.  Contact information will be used to administer your participation in a contest, notify the winners and award prizes.  Survey information will be collected and used for purposes of monitoring or improving the use and satisfaction of our products and services.

HOW WE SHARE YOUR INFORMATION AND WHOM WE SHARE IT WITH
During the course of business, we may disclose, transfer or otherwise make available your Personal Information (INCLUDING SENSITIVE INFORMATION) to our affiliates and third-party service providers who have been legally contracted to provide services on our behalf, and are prohibited from using it for any other purpose.  Personal Information is also shared with the Booking Engines referred to above in order to process your reservations and provide you with services.  Reservation Information is shared with the Booking Engines and our affiliates as discussed above.  Some of the recipients of your Personal Information as discussed above are located IN THE U.S., CANADA OR OTHER JURISDICTIONS.

We may share your Personal Information we collected for the purposes and in the manner described in this Privacy Policy with the following recipients.

  • Hard Rock’s headquarter in the United States for administration and management purposes;
  • our affiliates for providing the supplementary services to you;
  • our payment card processors which provide the payment services;
  • Dalian Luneng Real Estate Development Co., Ltd WHO IS OWNER OF OUR HOTEL PROPERTY AND Dalian Luneng Real Estate Development Company Golden Pebble Beach Hard Rock Hotel Management Branch Company WHO IS a subsidiary of the owning company actING as AN Asset Manager;
  • financial institutions which provide the transactions supporting and financial management services;
    prize fulfillment companies for granting prize or reward to you;
  • travel agencies which provide tourism planning and organization services;
  • survey research firms which conduct survey and collect responses for us;
  • Booking Engines for providing the reservation services to you.

You can exercise your rights under relevant laws and regulations against the recipients. If you have any issue with reaching to such recipients, you may contact us at dataprotection@hrh-dalian.com for such recipients’ contact information. 

In addition, to the extent permissible under applicable laws of China, we may share your Personal Information to local, state, federal and foreign countries as mandated by their reporting requirements; and governmental authorities to comply with legal, regulatory or administrative requirements, or as otherwise required by the U.S. or other law.  In such case, we will notify you of the name and contact information of the foreign recipients, their information processing purposes and methods and the types of personal information processed by them and other information, to the extent required under applicable law.  We may also disclose your Personal Information where necessary to prevent actual or suspected loss or harm to persons or property, or as otherwise permitted by law.

We may transfer your Personal Information as an asset in connection with the sale or transfer of all or part of the Hard Rock business (including transfers made as part of insolvency or bankruptcy proceedings) or as part of a corporate reorganization or other change in corporate control.  In such case, to the extent required under applicable law, we will notify you of the name and contact information of the recipient and require the recipient to continue to perform the obligations under relevant laws and this Privacy Policy, and if the recipient changes the original processing purposes or methods, we will require the recipient to obtain your consent.

HARD ROCK THIRD PARTY DISCLOSURE POLICY
We may, under limited circumstances, send you offers for related products or services from affiliated Hard Rock companies or jointly offered by Hard Rock together with select third parties.  These offers are sent only to those users who have given their consent of receiving marketing materials from Hard Rock.

CONSENT TO SHARING OF PERSONAL INFORMATION
AS A GLOBAL ORGANIZATION, DATA WE COLLECT MAY BE TRANSFERRED THROUGHOUT HARD ROCK'S WORLDWIDE ORGANIZATION TO HARD ROCK’S HEADQUARTERS IN THE UNITED STATES, OUR AFFILIATES AND OTHER THIRD PARTY SERVICE PROVIDERS AS LISTED ABOVE.  YOU EXPRESSLY AND VOLUNTARILY CONSENT TO SUCH TRANSFERS (INCLUDING CROSS-BORDER TRANSFERS) OF YOUR PERSONAL INFORMATION (INCLUDING SENSITIVE PERSONAL INFORMATION) TO THE RECIPIENTS IN THE ABOVE LIST AND FOR THE PURPOSES DESCRIBED IN THE ABOVE LIST AND THIS PRIVACY POLICY.  Without such consent, we are not able to provide you with access to our online reservation services and other programs.

PROTECTING CHILDREN
THE PERSONAL INFORMATION OF CHILDREN UNDER 14 YEARS OLD IS SENSITIVE PERSONAL INFORMATION.  We are mindful of the privacy of children as children merit specific protection with regard to their Personal Information, as they may be less aware of the risks, consequences and safeguards concerned and their rights in relation to the processing of Personal Information.  For these reasons, promotions activities by Hard Rock addressed to children always receive specific attention and protection.  We always get consent from the parents or other guardians of the children, where legally required, for processing of children's information.  

HOW TO ACCESS AND UPDATE USER INFORMATION
Users who no longer wish to receive our newsletter or promotional materials may opt out of receiving these communications by clicking the unsubscribe link at the bottom of the email or contacting dataprotection@hrh-dalian.com.

We aim to keep the Personal Information about you as accurate as possible.  If you would like to access, update, review or change the details you have supplied us with, please contact us at: dataprotection@hrh-dalian.com. In some cases we may need to use Personal Information obtained previously to verify your identity.

HOW WE ENSURE THE SECURITY OF YOUR PERSONAL INFORMATION
We have implemented technical, physical and administrative measures, as well as policies and procedures designed to safeguard your Personal Information from unauthorized access, use, disclosure, modification or destruction and will continue to update these measures as new technology becomes available.  

However, the Booking Engines or independent owners and operators of the Hard Rock Hotels are separately owned and operated from us, and therefore this Privacy Policy does not pertain to their policies and practices with respect to the Personal Information they collect and process.  Although we take efforts to protect your Personal Information and implement appropriate measures to supervise their processing of your Personal Information in accordance with the applicable law, we cannot firmly guarantee the security of your Personal Information collected by such Booking Engines or independent owners and operators.  Please consult the privacy policies of relevant Booking Engines or independent owners and operators regarding their policies and practices with respect to their measures to protect your Personal Information.

HOW LONG WE STORE YOUR PERSONAL INFORMATION
We will store your Personal Information for the minimum length of time required to fulfil the purposes stated in, or as prescribed by the applicable law.

HOW TO CONTACT US
You may address all communications to us via e-mail at dataprotection@hrh-dalian.com.  Please include your name, Address (only if you want us to reply to you by letter) and phone number or e-mail in all communications and state clearly the nature of your request.  If you wish to make a request to access the personal information we collect and store about you, please contact us at the email address above.

CHANGES TO OUR PRIVACY POLICY
This Privacy Policy is effective as of November 5, 2021.  If we make any changes to our Privacy Policy, we will post and provide the updated Privacy Policy when you first use the applet after the update, and may post it at other places we deem appropriate.  Users who have authorized e-mail communication will be notified via e-mail of any material changes to the Privacy Policy.  We will only use Personal Information in accordance with the Privacy Policy under which it was collected.