FONTAINEBLEAU.COM PRIVACY POLICY

Effective Date: May 25, 2018.

Welcome to the Privacy Policy of Fontainebleau Florida Hotel, LLC (“Fontainebleau” or “we”).

We appreciate that you trust us with your information. We want to make sure you understand the information we collect, how it is used and your choices regarding your information.

WHERE THIS PRIVACY POLICY APPLIES

This Privacy Policy applies to www.fontainebleau.com and any other website, application or other online services in or to which this Privacy Policy is linked or referenced (collectively, the “Services”). If a particular Service has its own privacy policy or links to a different privacy policy, then that privacy policy -- not this Privacy Policy -- applies.

Our agreements with certain customers may contain provisions about the collection, use, storage and disposal of information collected through the Services and offline. If a provision of a customer agreement conflicts or otherwise is inconsistent with a provision of this Privacy Policy, then the provision of the customer agreement will prevail but solely to the extent of the conflict or inconsistency

This Privacy Policy is incorporated into and made a part of our Terms of Service. If you have not done so already, please also review our Terms of Service.

DATA CONTROLLER

If you live in the European Economic Area, the data controller for the information you provide or that we collect is: Fontainebleau Florida Hotel, LLC, 4441 Collins Avenue, Miami Beach, Florida 33140 USA.

INFORMATION WE COLLECT

Information you provide to us
You choose to provide us with certain information:

When you create an account to use the Services, you provide us with your name and email address.
When you reserve a room, make an appointment for spa or other services or purchase a product - you provide us or the payment service with payment information, such as your credit card number, shipping address and similar information.
When you request information about our products and services.
When you choose to participate in our promotions, events or contests - we collect the information that you use to participate.
If you contact our customer service team - we collect the information you give us during the interaction. Sometimes, we monitor or record these interactions for training purposes and to ensure a high quality of service.
If you ask us to communicate with or otherwise process information of other people (for example, if you ask us to send a gift card) - we collect the information about others that you give us in order to complete your request.

Information we receive from others

In addition to the information you provide us directly, we receive information about you from others, including:

Business Partners: We may receive info about you from our partners, such as Shopify when you make a purchase or Cashstar when you purchase a gift card or when Fontainebleau ads are published on their websites (in which case they may pass along details on an ad campaign’s success).
Social Media: You may be able to use your social media login (such as Facebook Login) to connect with us. The social media platform shares some information from your social media account with us.
Our Related Companies: Fontainebleau is part of a family of businesses from which may obtain both personal and non-personal information.

Information collected when you use the Services
When you use the Services, we use collect information about which features you’ve used, how you’ve used them and the devices you use to access the Services.

Usage Information
We collect information about your activity on the Services, for instance how you use them (e.g., date and time you logged in, features you’ve been using, search queries, clicks and pages which have been shown to you, referring webpage address).
Device information
We collect information from and about the device you use to access the Services, including:
- hardware and software information such as IP address, device ID and type, device-specific and apps settings and characteristics, app crashes, advertising IDs, browser type and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser; and
- information on your wireless and mobile network connection, such as your service provider and signal strength.

Much of this information is collected using cookies and other data collection technology, as described below.

Other information with your consent
If you give us permission, we can collect your precise geolocation (latitude and longitude) through various means, depending on the service and device you’re using, including GPS, Bluetooth or Wi-Fi connections. The collection of your geolocation may occur in the background even when you aren’t using the services if the permission you gave us expressly refers to such collection. If you decline permission for us to collect your geolocation, we will not collect it. The Services use Google Maps to determine your location. When Google Maps is part of the services you choose to use, you are subject to Google’s Privacy Policy at http://www.google.com/policies/privacy.

COOKIES AND OTHER DATA COLLECTION TECHNOLOGY

The Services may use cookies, pixel tabs (also known as web beacons, flash cookies and clear GIFs) and similar technology (“Data Collection Technology”).

Cookies are small text files that are sent to or accessed from your web browser or your computer's hard drive. A cookie typically contains the name of the domain (internet location) from which the cookie originated, the “lifetime” of the cookie (i.e., when it expires) and a randomly generated unique number or similar identifier. A cookie also may contain information about your computer, such as user settings, browsing history and activities conducted while using the Services. A web beacon (also called a pixel tag or clear GIF) is a piece of computer code that enables us to monitor user activity and website traffic. To learn more about cookies and web beacons, visit www.allaboutcookies.org.

When we use Data Collection Technology, it helps us improve your experience of the Services by, for example, storing your password so you do not have to re-enter it each time you use the Services, measuring the success of marketing campaigns, compiling statistics about use of the Services and helping us analyze technical and navigational information about the Services and to detect and prevent fraud. We also may use other Data Collection Technology to collect information from the computer or device that you use to access the Services, such as your operating system type, browser type, domain and other system settings, as well as the language your system uses and the country and time zone in which your computer or device is located.

We also use Google Analytics, which is a Google service that collects aggregate information about use of the Services and reports website traffic and webpage use. Google Analytics does not directly identify individual users.

Your Control of Cookies
Some web browsers (including some mobile web browsers) provide settings that allow you to control or reject cookies or to alert you when a cookie is placed on your computer, tablet or mobile device. You also may be able to reject mobile device identifiers by activating the appropriate setting on your mobile device. Although you are not required to accept cookies or mobile device identifiers, if you block or reject them, you may not have access to all features available through the Services.

You can opt out of seeing online interest-based advertising from participating companies through the US Digital Advertising Alliance, European Interactive Digital Advertising Alliance, Digital Advertising Alliance of Canada and the Network Advertising Initiative. You can learn about Google’s advertising practices and opt out by visiting https://adssettings.google.com/authenticated or by downloading the Google Analytics opt-out browser add-on at https://tools.google.com/dlpage/gaoptout

Opting out does not mean you will not see advertising - it means you won’t see personalized advertising from the companies that participate in the opt-out programs. Also, if you clear your cookies, you need to opt-out again.

Our Policy on Do Not Track Signals
Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain Personal Information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many website operators, including Fontainebleau, do not respond to DNT signals.

HOW WE USE INFORMATION

How we use information depends on how you use the Services. We use information:

To administer your account and provide the Services to you

Create and manage your account.
Provide you with customer support and respond to your requests.
Complete your transactions.
Communicate with you about our products and services, including order management and billing.

To improve the Services and develop new ones

Administer focus groups and surveys.
Conduct research and analysis of users’ behavior to improve the Services and content (for instance, we may decide to change the look and feel or even substantially modify a given feature based on users’ behavior).
Develop new products and services.

To prevent, detect and fight fraud

Analyze data to better understand and design countermeasures against fraudulent activities.

To ensure legal compliance

Comply with legal requirements.
Assist law enforcement.
Enforce or exercise our legal rights.

To serve you relevant offers and ads

Administer discounts and other offers.
Develop, display and track content and advertising tailored to your interests on the Services and other sites.
Communicate with you by email, postal mail, telephone, social media or mobile device about products or services that we think may interest you.

To ensure a consistent experience across your devices

We may link the various computers and mobile devices you use so that you see the same information on all of them by linking your browser data, such as when you log into your account on different devices or by using partial or full IP address, browser version and similar data about your devices to help identify and link them. This linking helps us serve personalized advertising and other content that we think will interest you on both your mobile device and computer.

To process your personal information as described above, we rely on the following legal bases:

Legitimate interests: We may use your personal information when we have legitimate interests to do so. For example, we use your information to provide the products and services that you request and to market similar products and services.
Consent: From time to time, we may ask for your consent to use your information for certain specific reasons. You may withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy.

HOW WE SHARE INFORMATION

We share information as follows:

With our service providers and partners
We use third parties to help us operate and improve the Services. These third parties assist us on various tasks, including the performance of data hosting and maintenance, analytics, customer care, marketing, payment processing and security operations. We may also share information with partners who distribute and assist us in advertising the Services. All of our service providers must adhere to confidentiality obligations that are consistent with this Privacy Policy and the agreements we enter into with them.
With other affiliated businesses
We may share your information with our affiliates to help us with technical processing operations, such as data hosting and maintenance, customer care, marketing and targeted advertising, better understanding how our service is used and users’ behavior to improve our service, securing our data and systems, fighting against spam, abuse, fraud and intellectual property infringement.
For corporate transactions
We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.
When required by law
Applicable law may require us and our service providers to disclose your information if: (i) reasonably necessary to comply with a legal process, such as a court order, subpoena or search warrant, government investigation or other legal requirements; or (ii) necessary for the prevention or detection of crime (subject in each case to applicable law).
To enforce our legal rights
We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.
With your consent or at your request
We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information.

We may also use and share non-personal information (i.e., information that, by itself, does not identify who you are such as device information, general demographics, general behavioral data). We may share this information with our affiliates and third parties to analyze and report on advertising you see. We may combine this information with additional non-personal information collected from other sources.

YOUR CHOICES ABOUT YOUR PERSONAL INFORMATION

To update our records with your request for all marketing and promotional-offer emails to cease, please send an email to marketing@fontainebleau.com with the words "Email Removal Request" in the subject line. Please include your name and address in the body of the email.

To update our records with your request for all direct mail to cease, please contact us: (1) by sending an email to marketing@fontainebleau.com with the words “Direct Mail Removal Request” in the subject line. Please include your name and address in the body of the email; or (2) by sending your written request to: Marketing Department, Attention: Direct Mail Removal Request, Fontainebleau Resort, 4441 Collins Avenue, Miami Beach, FL 33140.

For all other requests to review, correct, update or delete personal information that you have previously provided to us or if you would like to suppress, restrict or receive an electronic copy of your personal information (if these rights are provided to you by applicable law), please contact us at myprofile@fontainebleauresorts.com.

In your request, please make clear what personal information you would like to have changed, whether you would like to have your personal information suppressed from our database or other limitations you would like to put on our use of your personal information. For your protection, we only fulfill requests when received from the email address associated with your account. We may need to verify your identity before fulfilling your request. Please note that we often need to retain certain information for recordkeeping purposes and/or to complete any transaction that you began prior to requesting a change or deletion. We also may not allow you to review certain data for legal, security or other reasons.

We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. The criteria used to determine our retention periods include:

The length of time we have an ongoing relationship with you and provide services to you (for example, for as long as you have an account with us or keep using the Services).
Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them).
Whether retention is advisable considering our legal position (such as, for statutes of limitations, litigation or regulatory investigations)

If at any time you believe that we have not adhered to this Privacy Policy, please let us know. We will use good faith efforts to determine and correct the problem.

If you are an EEA resident, you have the right to lodge a complaint with the data protection authority about how we process your personal information. For more information, please visit: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.

RESIDENT OF CALIFORNIA?

If you are a California resident, you can request a notice disclosing the categories of personal information about you that we have shared with third parties for their direct marketing purposes during the preceding calendar year. To request this notice, please submit your request (1) by sending an email to marketing@fontainebleau.com with the words “California Resident Request” in the subject line. Please include your name and address in the body of the email; or (2) by sending your written request to: Marketing Department, Attention: California Resident Request, Fontainebleau Resort, 4441 Collins Avenue, Miami Beach, FL 33140. Please allow 30 days for a response.

HOW WE PROTECT YOUR INFORMATION

We use physical, technical and organizational measures designed to protect your information against unauthorized access, theft and loss.

You are responsible for maintaining the security of your account and the information in your account. We may suspend your use of all or part of the Services without notice if we suspect or detect any breach of security. You understand and agree that we may deliver electronic notifications about breaches of security to the email address on record on your account.

If you believe that your account or information is no longer secure, please notify us immediately at marketing@fontainebleau.com.

CHILDREN'S PRIVACY

We do not knowingly collect personal information from anyone under the age of 18 because they are not allowed to use our services. If you know that a user is under the age of 18, please contact us at marketing@fontainebleau.com.

LINKS TO OTHER WEBSITES AND SERVICES

The Services may include links to third-party websites and services that are not operated by us. When you click these links, you will be directed away from the Services. A link to a third-party website or service does not mean that we endorse it or the quality or accuracy of information presented on it. If you decide to visit a third-party website or service, you are subject to its privacy practices and policies, not ours. This Privacy Policy does not apply to any personal information that you provide to these other websites and services.

CHANGES TO PRIVACY POLICY

The Effective Date of this Privacy Policy is set forth at the top of this webpage. As we add new features to the Services, we may amend this Privacy Policy. If we make a material change to this Privacy Policy that reduces your privacy rights, we will notify you in advance by sending you an email and/or posting a notice in the Services. Your continued use of the Services after the Effective Date constitutes your acceptance of the amended Privacy Policy. The amended Privacy Policy supersedes all previous versions.

HOW TO CONTACT US

If you have questions about the Services, please contact us at marketing@fontainebleau.com or Fontainebleau Florida Hotel, LLC, 4441 Collins Avenue, Miami Beach, Florida 33140.