UTW DIGITAL takes the issue of safeguarding your privacy seriously. Our Privacy Notice describes what

information we collect from our clients, as well as visitors to the UTWDIGITAL website, and the way in which

UTWDIGITAL uses this information to better serve your needs.

This Privacy Notice has been adopted by all of the distinct legal entities that manage and operate UTW DIGITAL

. What personal information do we collect?

Personal information is any information that may identify or relate to you as an identifiable individual. The

personal information that we collect about you could include:

Identity information – such as name, business name,

Contact information – such as your home address, zip/postal code, email addresses and phone number;

Images – such as CCTV images, publicly available photographs and images captured at events or during your stay

Financial and payment information – such as your credit card details, itemized spending and transaction history;

Reservation information – such as the type and location of the rooms you reserve and the dates of your

reservations;

Preference information – such as special requests, service issues and other preferences for your stay;

Public information – such as when we review public platforms to understand what you are saying about us or

the hospitality industry;

 

Technical information – such as information about the device you use to interact with us (including the unique

device identifier, hardware model, IP address, geolocation, operating system and version, and mobile network

information and unique device identifiers, in the case of our mobile App); and

Correspondence information – when you contact us, such as to send an enquiry or make a request, any

correspondence or application may be kept and added to your personal information.

How do we use your personal information?

For each of the categories of personal information described above, we use your personal information for the

following purposes:

to enable you to use our website .

to help us recognize or identify you and any accounts you hold with us;

to provide superior customer service to you.

to assist us in to providing the services you request at any of your properties

to process transactions through our website (including taking payment for purchases you may make through our

website) and to assist in any inquiries about your transaction.

for billing purposes in relation to your requests with us.

to confirm prior transactions and reconcile statements or invoices.

to contact you in relation to matters that arise from your services with us.

to send you newsletters or marketing communications regarding our services and to advise you of promotions

or to inform you of offers or other information that may be of interest to you (if, where required, you separately

provide your consent for us to do so).

to personalize and enhance your online experience.

to conduct surveys or focus groups to receive your views of our services delivery (if, where required, you

separately provide your consent to this).

to respond to a specific "Information Request" from you about one of our services and deal with any other

enquiries, correspondence, concerns or complaints you have raised.

for marketing, advertising and promotional purposes, such as through one of our on-line promotions or on third

party social networks, consistent with your preferences and applicable law.

if you become our client , to create an client profile that is stored in our data base systems.

to analyze customer trends and insights.

to operate our business, including for internal purposes such as auditing, data analysis, statistical and research

purposes and troubleshooting to help us improve our services.

On what basis do we use your personal information?

 

We use your personal information on the following basis:

 

to comply with legal and regulatory obligations, including financial reporting requirements imposed by

government regulators and our auditors.

to enter into agreements with you, and to perform our agreement to provide services to you when you work

with us.

for legitimate business purposes – using your personal information helps us to operate and improve our

business and minimize any disruption to the services that we may offer to you. It also allows us to make our

communications with you more relevant and personalized to you, and to make your experience of our services

more efficient and effective;

because you have given your consent – at times we may ask for your consent to allow us to use your personal

information for one or more purposes.

for purposes disclosed at the time you provide your personal information or as otherwise set forth in this

Privacy Notice; or for the establishment, exercise or defense of legal claims or proceedings.

How and from what sources is personal information collected?

For each of the categories of personal information and purposes described above, we gather information when

you provide it to us, or interact with us directly, for example:

when you create a profile or sign in to access an existing profile on our website .

when you make a purchase through our website;

We also collect your personal information while monitoring our technology tools and services, including

comment cards and email communications sent to and from UTW DIGITAL.

We may also receive information about you from other sources, such as our business partners and publicly

available sources. We combine information that we have about you from various sources, including the

information that you have provided to us.

Finally, we may collect your photograph from publicly available sources so that we can recognize you in order to

provide you with superior customer service.

Cookies and other data

We collect information automatically from you through the use of cookies, pixel tags and similar technologies,

when you visit our website or use our web-site read our emails, and we may use third party partners to collect

this device and usage information. For example, we collect information about how you use our website, such as

the pages you visit or links you click and if you use multiple devices, and information about the device you use,

such as the IP address, device type, operating system, and a unique ID that allows us to uniquely identify a

browser, mobile device or account (including, e.g., a persistent device identifier or AdID), and other such

information. If permitted by your device settings, we and our third party providers may collect location data

through GPS, Wi-Fi or other methods to personalize and enhance your online experience and to improve the

 

effectiveness of our website, mobile App, offers, advertising, communications and customer service. We collect

analytics data, or use third party analytics tools to help measure traffic and usage trends and to understand

more about the demographics and behaviors of our users.

 

We, or our third party partners, may use the data collected through cookies and similar technologies to

remember information so that you will not have to re-enter it during your visit or the next time you visit the

website or mobile App; provide custom, personalized content and information; identify and contact you across

multiple devices; provide and monitor the effectiveness of our website and mobile App and perform analytics;

diagnose or fix technology problems; detect or prevent fraud or other harmful activities, and otherwise to plan

for and enhance our online properties and services.

We may also use third party advertising companies to serve advertisements regarding goods and services that

may interest you when you access and use our websites and mobile App. To serve such advertisements, these

companies place or recognize a unique cookie on your browser (including through use of pixel tags). For more

information about our and our third party partners’ use of cookies and related technologies to collect

information automatically, please see our Cookie Notice.

How do we protect personal information?

We use a variety of physical, technical and administrative security measures and technologies to help preserve

the integrity and security of your personal information, consistent with applicable data protection and privacy

laws.

We endeavor to protect the privacy of your account and other personal information that we hold in our records,

but unfortunately, we cannot guarantee complete security. Unauthorized access or use, hardware or software

failure, and other factors, may compromise the security of user information. Also, while we endeavor to put

adequate contractual protections in place, we cannot guarantee the security of any personal information in

databases hosted by third parties.

It is important to note that any e-mail communication is not secure. This is a risk inherent in the use of e-mail.

Please be aware of this when requesting information or sending forms to us by e-mail (for example, from the

“Contact Us” section of our website). We recommend that you do not include any confidential information (e.g.

credit card information) when using e-mail. For your protection, our e-mail responses to you will not include any

sensitive personal information.

Finally, to be prudent, please be sure to always close your browsers when you are done using a form our web

site. Although the session will terminate after a short period of inactivity, it is best to close your browsers

immediately upon completion, especially when using a public computer.

Will personal information be provided to third parties?

For each of the categories of personal information, sources of information and purposes described above, we

may share certain of your personal information with:

Other third party service providers (Such as agents, contractors) to UTW DIGITAL.

 

online advertising partners, analytics and search engine providers that assist UTW DIGITAL in the improvement

and optimization of the website, or for advertising, analytics, attribution or research purposes (see our Cookie

Notice to learn more);

our professional advisors and auditors; and local or foreign regulators, governments, courts, law enforcement

and national security authorities.

Where a third party engaged by UTW DIGITAL processes personal information on our behalf, UTW DIGITAL takes

steps to contractually require these parties protect your personal information in a manner consistent with the

principles articulated in this Privacy Notice.

If you have chosen to join a subscription list, please note that they are only used for internal purposes and we

do not sell or rent our subscription lists to third parties for their direct marketing purposes.

We may also disclose information as may be required by law or legal process, or if we reasonably believe such

disclosure is necessary to comply with legal process or the reasonable requests of law enforcement or to

exercise or protect the rights, property or personal safety of the UTW DIGITAL, or others.

Transfers of your personal information outside your home country

Your personal information may be processed by UTW DIGITAL and its third party suppliers anywhere in the

world, including in countries where data privacy laws may not be equivalent to, or as protective as, the laws in

your home country.

We will implement appropriate measures to ensure that your personal information remains protected and

secure when it is transferred outside of your home country. These measures include data transfer agreements

implementing standard data protection clauses. You can find out more about data transfer agreements here.

Your rights

Depending on applicable law, which may be determined by your country, region or state of residency, you may

be able to exercise one or more of the following rights relating to our processing of your personal information.

You may also have other rights under the laws of your jurisdiction of residence.

To protect your personal information, we may require that you prove your identity to us at the time your

request is made. This may involve providing us with information which we hold on file about you (e.g. a home or

business address), or we may require you to produce some form of photo or government issued identification.

Accessing, correcting or deleting your personal information

We understand that you may like to know what personal information we hold about you, or to correct or delete

certain information we hold about you. We are happy to assist you with your request.

UTW DIGITAL reserves the right to decline a request to access, correct or delete your personal information under

certain circumstances as permitted by applicable law. In particular, there may be a variety of legitimate

business reasons why we may be unable to delete your personal information and where we are permitted to

decline your request to delete your information.

Right to decline marketing communications

If you do not wish to receive marketing communications from UTW DIGITAL, you may indicate your wishes by

send an e-mail to: info@utwdigital.com. You will always have the ability to accept or decline any form of

communication from UTW DIGITAL. You may unsubscribe from electronic marketing communications at any

time.

You may also be entitled to:

request the restriction of the processing of your personal information, or object to that processing;

opt out from the processing or disclosure of your personal information for direct marketing purposes;

Withdraw your consent to the processing of your personal information (where UTW DIGITAL is processing your

personal information based on your consent); and

request the receipt or transmission to another organization, in machine-readable form, of the personal

information you have provided to UTW DIGITAL.

Where you are given the option to share personal information with UTW DIGITAL, you can always choose not to

do so.

If you object to the processing of your personal information, or if you have provided your consent to processing

and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations.

This could mean that we are unable to perform the actions necessary to achieve the purposes of processing

described above (see ‘How do we use your personal information?’) or that you are unable to make use of the

services offered by us.

After you have chosen to withdraw your consent, UTW DIGITAL may be able to continue to process your

personal information to the extent required or otherwise permitted by law.

How long is my personal information retained?

Your personal information will be stored for the period of time required or permitted by law in the jurisdiction

of any company holding the information. This may involve retaining information following your stay. We will

delete your personal information once it is no longer reasonably necessary for any of the purposes described in

this Privacy Notice.

We will also keep your personal information where we need to do so in connection with a legal action or an

investigation involving Four Seasons.

Any financial information UTW DIGITAL retains will be protected under the terms of this Privacy Notice and,

where financing is arranged in the United States, under the Financial Services Modernization Act.

Third-Party Websites

Our websites and online services may include links to third party websites, plug-ins and applications. Except

where we post, link to or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to,

and we are not responsible for, any personal information practices of third party websites and online services or

the practices of other third parties. To learn about the personal information practices of third parties, please

visit their respective privacy notices.

 

Updates to this Privacy Notice

We will update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will

change the "Last Updated" date at the beginning of this Privacy Notice and will provide any other form of notice

as may be required by law. All changes shall be effective from the date of publication unless otherwise provided.