Effective Date: April 1, 2014
Special Note About Children
The Website is targeted for use by adults only.Miraval does not currently market to or create special areas for use by children. Accordingly, Miraval does not knowingly collect age identifying information, nor does Miraval knowingly collect any Personal Information (defined below) from children under the age of thirteen (13) years. However, we hereby advise all visitors to our Website under the age of thirteen (13) not to disclose or provide any Personal Information on our Website.In the event that we discover that a child under the age of thirteen (13) has provided Personal Information to us, in accordance with the Children’s Online Privacy Protection Act (please see the Federal Trade Commission’s website at http://www.business.ftc.gov/privacy-and-security/childrens-privacy for more information about this Act), Miraval will delete that person or child’s Personal Information from its files to the extent technologically possible.
In order to operate the Website and provide you with access to certain services that we offer through the Website, we collect, or engage third parties such as Sabre Inc. and Shopify, Inc., to collect the following types of information from you on our behalf: (1) personal information by which you may be identified (“Personal Information”) and (2) information about you and your activities on the Website that does not identify you personally (“General Information”), such as your domain server, the type of computer, web browser, operating system or platform you use and referrer data identifying the web pages you visited prior to and after visiting the Website, your movement and activity within the Website and your geographic location.
A. PERSONAL INFORMATION
When you provide your Personal Information to us or we collect it on your behalf, we may use your Personal Information to obtain additional information about you from third parties and to combine it with the information that you have provided or that we have collected on your behalf.
Personal Information about You Collected Directly from You
Miraval may collect your Personal Information when you interact with Miraval, its affiliates, or a third party, including Sabre Inc. and/or Shopify, Inc., through the Website, such as when you access various content, features, services, etc. The Personal Information Miraval may collect and maintain about you includes:
• Contact information, such as name, email address, postal address, telephone numbers, fax numbers.
• Your state/province and city.
• Unique identifiers, such as a customer number held in a cookie, an Internet Protocol (IP) address, a processor or device serial number, or other unique device identifiers.
• In certain circumstances, identity verification information, such as social security number or comparable national identifiers and driver’s license number, where needed to verify identity.
Personal Information about You Received from other Sources
Where permitted by applicable law, Miraval may collect information about you from other sources, including through interactive applications (such as mobile devices and third-party services), from commercially available sources (such as data aggregators and public databases) and when you access the Website through a SNS. Miraval may access and store some or all of the following Personal Information:
- Contact information, such as name, email address, postal address, telephone numbers, fax numbers.
- Your state/province and city.
- Unique identifiers, such as a customer number held in a cookie, an Internet Protocol (IP) address, a processor or device serial number, or other unique device identifiers.
- Your username and password for those services and other information available about or collected from you by those sources.
- In certain circumstances, identity verification information, such as social security number or comparable national identifiers and driver’s license number, where needed to verify identity.
- In limited circumstances, payment information, such as the last 4 digits of a credit card number, in connection with other identifying information. Miraval does not obtain full credit card numbers from any third-party.
In addition to collecting Personal Information from you, Miraval and our third party service providers may use a variety of technologies that automatically collect General Information that we use to offer a personalized experience of our Website and to manage our email programs. These techniques include:
- Web Beacons. Small graphic images or web programming codes called web beacons (also known as “pixel tags” or “clear GIFs”) may be included on the pages of the Website and in email messages we send you.Web beacons or other similar technologies may be used for a number of purposes, such as to count visitors to the Website, monitor how you navigate the Website or to count how many particular articles or links posted on the Website were actually viewed.
- Cookies. The Website may place small files, called “cookies” onto your computer.Cookies are data files that websites write onto computer hard drives for record keeping purposes when you visit them. The cookie file then identifies you as a unique user. Cookies make your use of this Website more pleasing and efficient by “personalizing” your Website experience and gathering Website statistical data, such as which parts of the Website you have previously visited, what material you downloaded, your Internet provider’s domain name and country, and the addresses of websites you visited immediately before and after our Website. They enable us to tailor the information you receive and to assist us or other third party organizations with whom we have strategic alliances by identifying you as our customer or Website user. Most web browsers automatically accept cookies, unless you have configured yours not to accept them. You can program your browser not to accept cookies, but if you do, you may not be able to use certain portions of the Website and the Website will not be able to customize certain features according to your preferences.
- Embedded Scripts. An embedded script is programming code designed to collect information about your use of this Website, such as the links you click on. The code is temporarily downloaded to your computer from our web server or a third party provider, is active only while you are connected to the Website and is deactivated or deleted once you leave the Website.
Do Not Track
Use of Your Information
- We use your information procured and maintained above for things that may include, but are not limited, to the following:
- To communicate with you.
- To provide you with products or services you request, or to provide information about offers that may interest you.
- To improve our Website services, provide technical, logistical or other services related to your use of the Website, or for other reasons, including to develop and provide advertising tailored to your interests.
- To provide marketing communications.
- To comply with any applicable laws and regulations.
- For any other purposes disclosed to you at the time we collect your information or pursuant to your consent.
Making an online reservation on the Website will link you to a third party reservation service provided by Sabre Inc.’s SynXis Hotel Central Reservation System (“Reservation System”). While it appears to be part of the Miraval Website, the Reservation System is provided by a third party – Sabre Inc. - and is governed by Sabre Inc.’s data privacy practices. Your security remains one of our primary concerns, and we have chosen the SynXis Reservation System with this goal in mind.
Making an online product purchase on the Website will link you to a third party e-commerce platform provided by Shopify, Inc. (“E-Commerce System”). While it appears to be part of the Miraval Website, the E-Commerce System is provided by a third party – Shopify, Inc. – and is governed by Shopify, Inc.’s data privacy practices. Your security remains one of our primary concerns, and we have chosen Shopify, Inc.’s E-Commerce System with this goal in mind.
Our Sharing of Your Information
We are committed to maintaining your trust and we want you to understand when and with whom we may share information collected about you. We may share General Information, such as aggregate user statistics, with our affiliated and non-affiliated third parties. We may share data, including Personal Information about you, with such third parties as disclosed at the time you provide your Personal Information and as set forth in the following circumstances:
- Third Party Service Providers.In some cases we may employ third party service providers, including, without limitation: data processors, marketing vendors and service providers, fulfillment houses, call centers, credit card processors, and hosting vendors, to perform certain services on our behalf, including, without limitation: (1) processing and fulfilling your reservations and product orders; (2) providing customer service; (3) shipping, sending postal mail and e-mails; (4) analyzing, updating and correcting information we receive on the Website; (5) performing business analysis, data processing and/or quality control; (6) providing marketing assistance, search results and links (including, without limitation, paid listings and links); (7) processing credit card and debit card payments; (8) hosting our databases; and (9) providing you with information you requested. Consequently, we may share your Personal Information with these third party service providers if they need it to perform services on our behalf.However, such third party service providers are not authorized by us to use your Personal Information for any other purpose.
- Disclosure of Customer Information for Legal and Administrative Reasons. We may disclose your Personal Information without notice: (1) when required by law or to comply with a court order, subpoena, search warrant or other legal process; (2) to cooperate in investigations of fraud, intellectual property infringement or any other activity that is illegal or may expose us or you to legal liability; (3) to comply with legal, regulatory or administrative requirements of governmental authorities (including, without limitation, requests from the governmental agency authorities to view your Personal Information); (4) to protect and defend the rights, property or safety of us, our affiliates, subsidiaries and partners and any of their officers, directors, employees, attorneys, agents, contractors and partners, and the Website’s users; and (5) to verify the identity of the Website’s users.
- Business Transfers. Your Personal Information may be transferred, sold or otherwise conveyed (“Conveyed”) to a third party where we: (1) merge with or are acquired by another business entity; (2) sell all or substantially all of our assets; (3) are adjudicated bankrupt or (4) are liquidated or otherwise reorganized. You consent to any and all such Conveyances of your Personal Information.
To the extent it is reasonably possible, Miraval provides choices regarding how your Personal Information is displayed in different community features on the Website, with settings that range from private to viewable by everyone. We also offer you a choice about whether to receive marketing communications from us. However, please note that, while you may control the level to which we personalize your experience, even if you unsubscribe to promotional offers or other marketing messages, we still may need to send you communications relating to your use of the Website, such as communications regarding transactions you initiate or for other legitimate non-marketing purposes.
Access and Updating Your Information
To update your Personal Information, Authentic Circle members should email changes to email@example.com. All others can email firstname.lastname@example.org to submit desired changes to your information.
In accordance with Miraval’s routine record keeping procedures, Miraval may delete certain records that contain Personal Information you have submitted through the Website. Miraval is under no obligation to store such Personal Information indefinitely and disclaims any liability arising out of, or related to, the destruction of such Personal Information.
How Long Your Information is Kept
Miraval generally keeps your data on the Miraval servers or in the Miraval archives for as long as Miraval reasonably needs it. Miraval may alter this practice according to changing requirements.For example, Miraval may delete some data if needed to free up storage space.Miraval may keep other data for longer periods if applicable law requires it. In addition, information posted in a public forum could stay in the public domain indefinitely.
Data management requests are administered in an orderly manner to the extent feasible and within Miraval’s direct control. Please note that Miraval has greater control over recently collected data than over archived data. Once data is removed from the system and archived, it may not be feasible to accommodate specific requests. In those cases, Miraval’s general data retention policy applies.
Consent to Transfer
Our Website and services are operated in the United States. If you are located in Canada or elsewhere outside of the United States, please be aware that information we collect will be transferred to and processed in the United States. By using our Websites or services, or providing us with any information, you consent to this transfer, processing and storage of your information in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen.
Safeguarding Your Information
To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, Miraval uses appropriate industry-standard procedures to safeguard the confidentially of your Personal Information, including physical, technical and procedural safeguards. However, you should assume that no data transmitted electronically can be 100% secure. Therefore, although we believe the measures implemented by us reduce the likelihood of security problems to a level appropriate to the type of data involved, Miraval does not promise or guarantee, and you should not expect, that your Personal Information or private communications will remain private.
Links to Third Party Websites
While on the Website or when viewing an email or other content provided by Miraval or the Website, you may encounter links to other websites operated by third parties. These other website may set their own cookies, collect data or have their own privacy policies and practices.Miraval is not responsible for the privacy practices or the content of such third party websites and Miraval encourages you to review the privacy policies of these websites as soon as you enter them. Links to any third party websites or content do not constitute or imply an endorsement or recommendation by Miraval of the linked websites or content.
California Residents’ Privacy Rights
Companies that collect Personal Information from California residents and disclose such information to third parties for marketing purposes must, in response to a request by a consumer, either (1) provide a list detailing the categories of information shared and the entities to which such information was provided, or (2) provide a mechanism by which a consumer may opt out of having his or her information shared with third parties. We have elected the second option, and you may request that your Personal Information not be shared with third parties by sending your request, including your full name, email address and postal address, to Miraval using the contact information below. California residents are entitled to know that they may file grievances and complaints with California Department of Consumer Affairs, 400 R Street, Suite 1080, Sacramento, CA 95814; or by phone at 916-445-1254 or 800-952-5210; or by email to email@example.com.
Changes to this Policy
Miraval Resorts may change or supplement our policies, content, information, promotions, disclosures, disclaimers and features at any time and without prior notice at the sole and absolute discretion of Miraval Resorts. Changes to this Policy will be posted on this webpage and we will revise the “effective date” at the top of this Policy.
If we make any material changes in the way we collect, use, and/or share personal information that may impact you, we will notify you by sending an email to the email address you most recently provided to us (unless we do not have an email address for you) and/or by prominently posting notice of the changes on this Website. Your continued use of the Website following such material changes requires your affirmative consent to the changes. If you do not agree to the changes, your sole remedy is to cease using the Website.
How to contact us
If you have any questions or concerns about our policy or its implementation, you may contact us at this email address: firstname.lastname@example.org.