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Privacy Policy

  1. Introduction
    We use your personal information in order to fulfil our commitment to providing an unparalleled guest service experience in connection with all of your interactions with Lumiere (the "Purpose"). As part of that undertaking, we are committed to safeguarding the privacy of the personal information that we gather. As one of our guests or someone else with whom we do business, you understand and agree that we collect, use, and disclose your personal information in accordance with this Global Privacy Policy (this "Policy").
  2. The Application of this Policy

    This Policy applies to personal information regarding guests and the other individuals with whom we do business or who visit us and to the use of that personal information in any form – whether oral, electronic, or written.

    This Policy gives effect to our commitment to protect your personal information and has been adopted by all of the separate and distinct legal entities that manage, operate, franchise, license, own and/or provide services to Lumiere Hotel. Those entities include Lumiere Hotel and its direct and indirect subsidiaries, and all of the separate and distinct legal entities that own the Lumiere Hotel properties worldwide or provide services to you under a Lumiere brand. References to "Lumiere", "we" and "our" throughout this Policy, depending upon the context, collectively refer to those separate and distinct legal entities. While this Policy is intended to describe the broadest range of our personal information processing activities globally, those processing activities may be more limited in some jurisdictions based on the restrictions of their laws. For example, the laws of a particular country may limit the types of personal information we can collect or the manner in which we process that personal information. In those instances, we adjust our internal policies and/or practices to reflect the requirements of local law.

  3. Types of Personal Information We Collect

    The term "personal information" in this Policy refers to information that does or is capable of identifying you as an individual. The types of personal information that we process (which may vary by jurisdiction based on applicable law) include:

    • your name, gender, personal and work contact details, business title, date and place of birth, image, nationality, and passport and visa information;
    • guest stay information, including dates of arrival and departure, goods and services utilised, special requests made, observations about your service preferences (including room and vacation preferences), telephone numbers dialed and faxes, texts and telephone messages received;
    • your credit card details;
    • any information necessary to fulfil special requests (e.g. health conditions that require specific accommodation or services);
    • information, feedback or content you provide regarding your marketing preferences, in surveys, contests, or promotional offers, or to our website and those of third parties;
    • information collected whilst at Lumiere Hotel through the use of closed circuit television systems, internet systems (including wireless networks that collect data about your computer, smart or mobile device, or your location), key card and other security and technology systems;
    • information collected whilst you access the Lumiere website (we describe this in more detail in Sections 7 and 8 below);
    • contact and other relevant details concerning the employees of corporate accounts and vendors and other individuals with whom we do business (e.g. travel agents or meeting and event planners); and
    • in limited cases, information relating to the credit of customers.

    Much of the personal information we process is information that you or someone acting on your behalf knowingly provides to us. However, in other instances, we process personal information that we are able to infer about you based on other information you provide to us or during our interactions with you, or personal information about you that we receive from a third party. This Policy also applies to the personal information about you that we receive from a third party, unless specifically covered by such third party's privacy policy.

    There may be instances in which the personal information that you provide to us or that we collect is considered Sensitive Personal Information under the privacy laws of some countries. Those laws define "Sensitive Personal Information" to mean personal information from which we can determine or infer an individual's racial or ethnic origin, political opinions, religious beliefs or other beliefs of a similar nature, membership in a trade union or professional association, physical or mental health or condition, medical treatment, genetic data, sexual life, or judicial data (including information concerning the commission or alleged commission of a criminal offence). In some very rare instances, financial records may form part of Sensitive Personal Information where you are located. We only process Sensitive Personal Information in your jurisdiction if and to the extent permitted or required by applicable law.

    When you agree to this Policy you are, to the extent required under your local law, granting your express and written consent to the processing of any personal information that you provide to Lumiere that is considered to be Sensitive Personal Information or financial information. Save to the extent required by law, you are not obliged to provide Lumiere with any of your Sensitive Personal Information, and should you choose not to, this will not prevent you from purchasing any products or services from Lumiere.

  4. How We Use Personal Information

    Subject to applicable laws, we may collect, use and disclose relevant portions of your personal information in order to:

    • provide and charge for hotel accommodation and other goods and services;
    • provide you with a better or more personalised level of service, including information and services from a third party (such as additional guest services at Lumiere Hotel, local attractions and transportation options);
    • respond to requests for information and services, including services from a third party (such as restaurants or transportation providers);
    • fulfil contractual obligations to you, anyone involved in the process of making your travel arrangements (e.g. travel agents, group travel organisers or your employer), and vendors (e.g. credit card companies, airline operators, and third party loyalty programs);
    • conduct market research, customer satisfaction and quality assurance surveys, and direct marketing and sales promotions;
    • provide for the safety and security of staff, guests and other visitors;
    • administer general record keeping;
    • meet legal and regulatory requirements;
    • test and evaluate new products and services; and
    • process credit applications.

    Lumiere uses and retains your personal information for as long as is necessary to fulfil the Purpose.

  5. Disclosures of your Personal Information

    From time to time, we may disclose your personal information. We would always make that disclosure in accordance with applicable law. In some jurisdictions, data privacy laws may require us to obtain your consent before we transfer your information from your originating country to other countries. When you agree to this Policy, you are, to the extent required and permitted under your local law, granting your consent to the transfer of your personal information to such other countries for the Purpose and to the extent stated in this section and as described in Section 4 above.

    Circumstances where we might make such disclosure (in addition to those described in Section 4 above) include:

    5.1 Our Agents, Service Providers and Suppliers
    Like most international hotel brands, we may outsource the processing of certain functions and/or information to third parties. We may also engage market research firms to assist us in contacting guests for the purpose of market research and quality assurance. When we do outsource the processing of your personal information to third parties or provide your personal information to third-party service providers, we oblige those third parties to protect your personal information in accordance with the terms and conditions of this Policy, with appropriate security measures.

    5.2 Consumer Insights
    Where we hold personal information about you, we may disclose this personal information to other companies that also hold information about you. These companies may combine the information in order to better understand your preferences and interests, thereby enabling them and us to serve you better. If your personal information is used for direct marketing purposes, you have the right to object to that by contacting us using the contact information provided under Section 10 below.

    5.3 Credit Authorisation
    When you request credit, your personal information will be used and disclosed to appropriate third parties in accordance with applicable laws for the purpose of determining whether to grant and maintain a line of credit to you.

    5.4 Business Transfers
    As we continue to develop our business, we may sell hotels and other assets, or cease being the manager or franchisor of a hotel that is currently part of our portfolio. In those circumstances, we may include the personal information collected about you, or control of that personal information, as a business asset in any such transfer. Also, in the unlikely event that we, or substantially all of our assets, are acquired, personal information collected about you, or control of such information, may be one of the transferred assets.

    5.5 Legal Requirements
    We reserve the right to disclose any personal information we have concerning you if we are compelled to do so by a court of law or lawfully requested to do so by a governmental entity or if we determine it is necessary or desirable to comply with the law or to protect or defend our rights or property in accordance with applicable laws. We also reserve the right to retain personal information collected and to process such personal information to comply with accounting and tax rules and regulations and any specific record retention laws.

  6. Centralised Data Processing Activities
    Like most international businesses, we have centralised certain aspects of our data processing activities in accordance with applicable laws, which, in many instances, will result in the transfer of your personal information from one country to another. The jurisdictions where that information will be processed may or may not have laws that seek to preserve the privacy of personal information. Nevertheless, whenever your personal information is transferred within the Lumiere companies, your personal information will be processed in accordance with the terms and conditions of this Policy and applicable laws.
  7. Information We Collect When You Visit Us Online

    If you access the Lumiere website, you may wish to know the following:

    7.1 You Can Browse Without Revealing Who You Are
    You can access our website without logging in or otherwise revealing who you are.

    7.2 Usage Information
    When you visit our website, we collect information about how you use the website. Examples of such information include the Internet Protocol address automatically assigned to your computer each time you browse the Internet, the date and time of your visit, the pages you access and the amount of time you spend on each page, the type of Internet browser you use, your device's operating system and the URL of any websites that you visited before and after visiting our website. That information is not linked to you as an individual, but we may keep records of the device being used.

    7.3 Cookies and Other Similar Technology
    We use cookie technology on our website to allow us to evaluate and improve the functionality of our website. Cookies by themselves cannot be used to reveal your identity. They identify your browser, but not you, to our servers when you visit our websites.

    If you do not want to accept cookies, you can block them by adjusting the settings on your Internet browser. However, if you block them, you may not be able to use all of the features of our website.

    7.4 Social Media
    Our website may also contain plug-ins and other features that integrate third party social media platforms into our website. You will be able to activate them manually. If you do so, the third parties who operate these platforms may be able to identify you, they may be able to determine how you use this website and they may link and store this information with your social media profile. Please consult the data protection policies of these social media platforms to understand what they will be doing with your personal data. If you activate these plug-ins and other features, you will be doing so at your own risk.

    7.5 Security
    Because the security of your personal information is important to us, we use Secured Socket Layer ("SSL") software in order to encrypt the personal information that you provide to us. If your browser is SSL enabled (which most are), your transmission of personal information to us online will be encrypted. You can verify whether your personal information is transmitted using SSL encryption by confirming the symbol of a closed lock or solid key on the bottom bar of your browser window. You can also verify that your personal information will be encrypted using SSL encryption by making sure that the prefix for the web address listed for that page has changed from "http" to "https". If you do not see the appropriate symbol and the "https" prefix, you should not assume that the personal information that you are being asked to provide will be encrypted prior to transmission.

    The personal information we collect from you online is stored by us and/or our service providers on databases protected through a combination of physical and electronic access controls, firewall technology and other reasonable security measures. Nevertheless, such security measures cannot prevent all loss, misuse or alteration of personal information and we are not responsible for any damages or liabilities relating to any such incidents to the fullest extent permitted by law. Where required under law, we will notify you of any such loss, misuse or alteration of personal information that may affect you so that you can take the appropriate actions for the due protection of your rights.

    7.6 Minor Children
    Our website does not sell products or services for purchase by children and we do not knowingly solicit or collect personal information from children. If you are under the age of 18 (or a minor in the jurisdiction in which you are accessing our websites), you may only use our website with the involvement of a parent or guardian.

    7.7 Targeted Advertising
    Where permitted by law, we may work with other companies to show you advertisements we think you may find relevant and useful. This may include advertisements displayed on our own website, or advertisements from us displayed on other companies' websites. The advertisements you see may be based on information collected by us or third parties and/or may be based on your activities on our websites or third-party websites.

    The personal information we collect from you online is stored by us and/or our service providers on databases protected through a combination of physical and electronic access controls, firewall technology and other reasonable security measures. Nevertheless, such security measures cannot prevent all loss, misuse or alteration of personal information and we are not responsible for any damages or liabilities relating to any such incidents to the fullest extent permitted by law. Where required under law, we will notify you of any such loss, misuse or alteration of personal information that may affect you so that you can take the appropriate actions for the due protection of your rights.

  8. Choice

    You may always choose what personal information (if any) you wish to provide to us. However, if you choose not to provide certain details, some of your experiences with us may be affected (for example, we cannot take a reservation without a name).

    If you provide us with your contact details (e.g. postal address, email address, telephone number or fax number), we may contact you to let you know about the products, services, promotions and events offered that we think you may be interested in. We may also ask you to indicate how you would like to receive any offers, marketing and promotional information (e.g. via email or regular mail) and whether you would be willing to participate in surveys. We may also share your personal information with carefully-selected third parties, who may communicate directly with you. In some jurisdictions, data privacy laws may require us to obtain a separate consent before we do so. You can always choose whether or not to receive any or all of these communications by contacting us as described in Section 10 below or following any "unsubscribe" instructions contained in the communications.

    In some jurisdictions, in addition to you agreeing to this Policy, data privacy laws may require us to obtain a separate consent before we send you information that you have not specifically requested. In certain circumstances, your consent may be implied (e.g. where communications are required in order to fulfil your requests and/or where you have volunteered information for use by us). In other cases, we may seek your consent expressly in accordance with applicable laws (e.g. where the information collected is regarded to be Sensitive Personal Information under local regulations).

    We will abide by any request from you not to send you direct marketing materials. When such a request is received, your contact details will be "suppressed" rather than deleted. This will ensure that your request is recorded and retained unless you provide a later consent that overrides it.

  9. Changes to this Policy

    Just as our business changes constantly, this Policy may also change. To assist you, this Policy has an effective date set out at the end of this document.

  10. Request for Access to Personal Information/Questions or Complaints

    If you have any questions about this Policy, about the processing of your data described, or any concerns or complaints with regard to the administration of the Policy, or if you would like to submit a request for access to or deletion of the personal information that we maintain about you, please contact us by any of the following means:

    • by calling one of the following toll-free reservation numbers located at the Customer Service page on thelumierehotel.com; by mail at Building No. 26, St. 55, Corner St. 228, Sangkat Chaktomuk Khan, Daun Penh or
    • by contacting the front desk at any of our hotels.

    If you are not satisfied with the response that you receive, you can escalate your concern to the Chief Privacy Officer by sending an email to info@thelumierehotel.com

    While this Policy alone does not create contractual rights, Lumiere has ensured compliance with some of its legal obligations in some countries in relation to personal information by creating a set of binding standards and policies (known in some countries as binding corporate rules), approved by a number of national privacy regulators. As a result, depending on your circumstances and location, you may be able to enforce your privacy rights using those standards or policies through that regulator or a court. If you would like to know more about these standards and policies, please contact Lumiere Hotel at the address above or the Chief Privacy Officer at the email address above.

    All requests for access to your personal information must be submitted in writing by letter or email. We may respond to your request by letter, email, telephone or any other suitable method.

    In the event of any inconsistencies between the English version of this Policy and any version of this Policy in any other language, the English version shall prevail (to the fullest extent permitted under applicable law).

  11. Effective Date: 9 February 2017

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