Eaton Workshop

LegalEaton Workshop and its affiliates (collectively, “Eaton”, “we”, “us”, “our”, and “our Group”) respect the privacy of all our customers and business partners and treat personal information (personal data) provided by you to us as confidential. We know that you are concerned how information about you is collected, processed, used and stored, and we appreciate you trusting that we will do so with every due care and diligence.We have provided this Privacy Policy as an explanation of the information we collect, how we process and use it, and how the use of this information can benefit your experience on our web sites and products and services we provide. <h2>1. What information about you do we collect</h2>In order for us to operate effectively and provide you with the best experiences with our services, we may request and collect information about you, whether as hotel guests, website visitors or you contacting us for any other purposes, that includes personal information that can identify you as an individual.Your personal information can come to us via various channels, including but not limited to:<ul><li>when you browse and interact with our websites and/or use any mobile apps that we may make available - such as make a booking via our Online Reservation system, make an inquiry, sign up for newsletter subscription or make brochure requests or download and use our mobile apps</li><li>through your use of our products and services – such as when you stay as a guest or visits the hotels, restaurants or facilities managed by us</li><li>when you submit inquiries to us or provide us with your feedback</li><li>when you participate in our promotional offers, competitions or surveys</li><li>from third parties – such as partners we work with or public databases – where you have provided your consent to the third party or to us so that information sharing taking place or where we have a legitimate interest to use the personal information in order to provide you with our products and services</li></ul>The types of personal information that we collect and process may include, but not limited to (and may vary by jurisdiction):<ul><li>personal details, such as your name, gender, date of birth, nationality, passport and visa information, personal and work contact details (addresses, emails and telephone numbers)</li><li>payment and credit card information, such as bank accounts, name of cardholder, credit card number, credit card billing address and expiry date</li><li>guest stay information and lifestyle information, such as hotels where you have stayed, arrival and departure dates, room preferences, leisure activities, names and ages of children, observation of your services preference, and other information necessary to fulfil special requests</li><li>information, feedback or content you provide regarding your interests and preferences</li><li>information from our security systems such as from our closed-circuit television system, card key, internet login and firewalls</li><li>information relating to your use and interaction with our websites and mobile apps</li></ul>Some of the personal information which you provide to us are considered “sensitive personal information” under the privacy and data protection laws in specific jurisdiction – such as personal information from which we can determine or infer an individual’s racial or ethnic origin, health or biometric data. We only process sensitive personal information in such jurisdiction if and to the extent permitted or required by applicable law.Except where required by local laws, we do not knowingly collect personal information from our websites from any children or minors. As a parent or legal guardian, please do not allow your children or minors to submit personal information without your permission. We may also collect non-personally identifiable information about you, such as internet log information or visitor behavior patterns when you visit our websites on your use of our websites, communication preferences, travel habits, aggregated data relative to your stays, and responses to promotional offers and surveys. Please also refer to our Cookies policy. <h2>2. What information about you do we collect</h2>We may collect, process and/or use the personal information which we collect in order to:<ul><li>deliver our products and services to you – such as completing your reservations, sending you reservation confirmations, supplying the purchased goods and services, fulfilling a request for information, customizing our services to your preferences, keeping proper records of your transactions with us</li><li>communicate and provide marketing and promotion to you – such as sending you information and updates on our products and services and other products and services that we think may be of interests to you, including latest promotions, competitions, joint- and cross promotions with our business partners, response to inquiries, to send you important information regarding our websites, changes to our terms, conditions and policies</li><li>develop and improve our services to you – such as performing market research, analytics and/or profiling, developing new products and services, improve the effectiveness of our websites, your hotel experience, our various types of communications, advertising campaigns, and promotional activities</li><li>work and cooperate with third party parties to deliver our products and services to you – such as travel agents, group travel organization, or anyone involved in the process of making your travel arrangements, credit card companies, airline operators and third-party loyalty programs</li><li>maintain your safety and security as well as that of other guests and personnel – such as to make proper identification and verification in processing of transaction, implement security surveillance and access controls when you visit or stay at our hotels, and administer general record keeping</li><li>meet applicable legal and regulatory requirements</li><li>use it in other ways as required or permitted by law or with your consent</li></ul>We will only collect, process and/or use the personal information where we are satisfied that we have an appropriate legal basis to do so. This may be because (i) you have provided your consent, (ii) our use of information is necessary for providing the products and/or services you have requested, (iii) our use of your information is in our legitimate interest as a commercial organization, such as to operate and improve our services (including for profiling and targeted advertising) and in a way proportionate and respects your privacy rights, and/or (iv) necessary compliance with applicable laws, regulations, court orders or other legal process. <h2>3. Keeping and safeguarding of personal information</h2>To the extent permissible by applicable law, we generally only keep your information for as long as is reasonably required for:<ul><li>the purposes for which that personal information was provided</li><li>ongoing business need, including record keeping, fraud prevention, or if we reasonably believe there is a prospect of litigation</li><li>as necessary to meet legal, regulatory, tax or accounting needs</li></ul>We take reasonable steps to safely and securely delete, dispose of, anonymize and/or block personal information when we no longer need it.Information security: We endeavor to protect your personal information we maintain and have implemented reasonable technical, organizational and administrative measures to keep your personal information safe and secure and to protect it against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We will review, monitor and update these security measures to meet our business needs, changes in technology and regulatory requirements.Information transfer overseas: We do business globally. In order for us to operate effectively and provide you with the best experiences with our services, we may centralize certain aspects of our information processing activities and may have databases in different countries (some of which are operated by our local group company and some of which are operated by third parties on our behalf). We may therefore have to share and transfer your personal information from one country to another, or even across multiple jurisdictions, such as:<ul><li>in or to Hong Kong where our corporate office is located</li><li>in those countries in which we manage and operate hotels, residences, sales or representative offices</li><li>in those countries where our third-party suppliers and/or services providers, agents, advisors or consultants are located</li></ul>Your personal information may therefore be subject to privacy laws that are different from those in the country where the personal information is collected or those in your country of residences. We will endeavor that the transfer of your personal information is carried out in accordance with applicable privacy laws and that appropriate technical, organization and administrative measures are in place for its safeguard.Information sharing: Insofar as reasonably necessary for us in delivering our products and services to you and for the purposes set out in this Privacy Policy, we may share your personal information with the below parties. The specific kind of information we share will depend on your activities with us and only to the extent as required or permitted by law, and/or with your consent.<ul><li>our group entities, hotels and residences managed and operated by us</li><li>our business partners and third parties involved in the delivery of our products and services to you – including those involved in a sale of all or part of our business operations or assets and those for business, operational and general administration</li><li>our marketing and advertisement partners</li><li>third-party services providers which process data (including personal information) for us, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures</li><li>our agents, advisors, consultants, other third-party suppliers and/or services providers to assist us to operate effectively and provide you with the best experiences with our services</li><li>other third-parties when we have your consent or are otherwise permitted by law to do so</li></ul>Information processing by third parties: Like most international hotel brands, we may outsource the processing of certain functions and/or information to third parties, which may be located in countries other than the country where your information is collected or your country of residences. We may also engage market research firms to assist us in contacting our 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 services providers, we oblige those third parties to protect your personal information with appropriate security measures. <h2>4. You control your personal information</h2>You may always choose what personal information (if any) you wish to provide to us. Please note, however, some of our products and services to you may be affected if you choose not to provide certain details, for example, we cannot reply to you without a name or contact details.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. You can always choose whether or not to receive any or all of these communications by contacting us as described in Section 8 below. In addition to you agreeing to this Privacy Policy, we may also ask you to give us a separate consent before we send you with this information or indicate how you would like to receive any communication (e.g. via email or regular mail). After you have indicated your preferences, you can always change them.You may be aware that the European Union General Data Protection Regulation gives certain rights to individuals in relation to their personal information - including the right of access to the personal information we hold about them, right of rectification, right to erasure, right to restrict data processing, right to object to processing, right to data portability, right to complain to a supervisory authority, and right to withdraw consent.If you wish to exercise any of your rights in relation to your personal information, please contact us as described in Section 6 below. <h2>5. Other relevant information</h2>Cookies: To enhance your experience on our websites, some of our web pages may use "cookies". Cookies are text files that we place in your computer's browser to store your preferences. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you choose to reject cookies, you may not be able to use certain of our online products and services or website features. Cookies, by themselves, do not tell us your e-mail address or other personally-identifiable information unless you choose to provide this information to us by, for example, registering for one of our services. However, once you choose to furnish the site with your personal information, this information may be linked to the data stored in the cookie.We may use cookies for the following purposes:<ul><li>to understand site usage and to improve the content and offerings on our websites. For example, we may use cookies to personalize your experience at our web pages (such as to recognize you by name when you return to our sites), save your username and/or password in password-protected areas, and to offer you products, programs, or services.</li><li>to maintain continuity during a user session</li><li>to gather data about the usage of our websites for research and other purposes</li><li>to store your preferences for certain kinds of information and marketing offers</li><li>Our cookies will track only your activity relating to your online activity on the websites and will not track your other Internet activity. Our cookies do not gather personal data. You can decide if and how your computer will accept a cookie by configuring your preferences or options in your browser.</li><li>We may occasionally permit other companies to set cookies on our websites and gather cookie information for us. In some cases, we may also use another company to operate web servers or process credit card purchases for our websites. We use the cookie information gathered by these companies in the same manner as stated above.</li></ul>Web Beacons: Pages of our services or our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us to monitor the activity of our websites and e-mails. For example, to count users who have visited those pages or opened an e-mail and for other related website statistics.Clickstream Data: Clickstream data is information collected by our computers when you request Web pages from the Sites. Clickstream data may include information such as the page served, the time spent viewing the page, source of the request, type of browser making the request, the preceding page viewed and similar information. Clickstream data permits us to analyze how visitors arrive at our websites, what type of content is popular, what type of visitors in the aggregate are interested in particular kinds of content on the websites.Links to other websites: For your convenience and information, we provide links to external third-party websites, including websites owned or controlled by independent franchisees, third party owners of hotel, resort, interval ownership, or residence properties that may use our brand name(s), or websites not controlled or authorized by us. The linking of external third-party websites to this website does not indicate any association with or endorsement from us. We cannot always ensure, and are not responsible or liable for, any content of these external third-party websites, including, but not limited to, any advertising claims or marketing practices. Please note this Privacy Policy is limited to our own information collection practices. We strongly recommend that you read the separate privacy and security policies and the information collection practices of any external third-party website before providing any personal information while accessing those websites. <h2>6. How to contact us</h2>For any questions, concerns or requests regarding this Privacy Policy or our information collection practices, please email us at <a href="mailto:privacy@eatonworkshop.com" target="_blank">privacy@eatonworkshop.com</a> or write us at:Eaton Workshop1201 K St NWWashington DC, 20005+1 202 289 7600 <h2>7. About this Privacy Policy</h2>This Privacy Policy is effective from 25 May 2018. From time to time, we may have to update, change, modify or amend this Privacy Policy. Subject to any applicable legal requirements to provide additional notice, when we make material changes to this Privacy Policy, we will provide you with notice as appropriate under the circumstances such as through our websites or by sending you an email. Legal DisclaimerIn addition to our rights of disclosure as mentioned hereinabove, we may also disclose your personal information when required by law or court order, or as requested by other government or law enforcement authorities, or in the good faith that disclosure is otherwise necessary or advisable including and without limitation to protect the rights or properties of our Group. This also applies when, in compliance with applicable laws, we have reason to believe that disclosing the personal information is necessary to identify, contact or bring legal action against someone who may be causing interference with our rights or properties, whether intentionally or otherwise, or when anyone else could be harmed by such activities. ContentsThe information and material contained in this site are for general references only. Our Group disclaims any warranty or representation of any kind, express or implied, as to any matter whatsoever relating to this site or any linked site. To the fullest extent allowed by law, our Group shall accept no responsibility or liability in respect of any loss or damage howsoever arising.Use of or visit this site does not constitute any binding contract over any goods and services provided by our Group, nor does it constitute an offer of any goods and services provided by our Group. Goods and services may only be available in certain countries and any offer to purchase goods or to retain services from our Group are subject to acceptance by our Group and in accordance with specific terms and conditions on which they are offered. <h2>COOKIES POLICY</h2>To enhance your experience on our web site, some of our web pages may use "cookies." Cookies are text files that we place in your computer's browser to store your preferences. Cookies, by themselves, do not tell us your e-mail address or other personally-identifiable information unless you choose to provide this information to us by, for example, registering for one of our services. However, once you choose to furnish the site with your personally-identifiable information, this information may be linked to the data stored in the cookie.We use cookies to understand site usage and to improve the content and offerings on our sites. For example, we may use cookies to personalize your experience at our web pages (e.g., to recognize you by name when you return to our site), save your username and/or password in password-protected areas, and to offer you products, programs, or services.Read more about the types of cookies used on our website and how you can manage your cookies. <h2>Performance:</h2>Cookie: Adobe AnalyticsName: s cc, s sq, s_vi, s_fidDuration (Expiration): VariesPurpose: We use Adobe Analytics to help study user behavior on the website in order to improve the site for our users.We use Adobe Analytics to help study user behavior on the website in order to improve the site for our users. For more information about the data practices of Adobe Analytics, please visit their <a href="https://marketing.adobe.com/resources/help/en_US/reference/index.html?f=c_privacy_overview" target="_blank">privacy policy</a>To opt out, please go <a href="https://marketing.adobe.com/resources/help/en_US/sc/implement/opt_out.html" target="_blank">here</a> Cookie: Adobe TargetName: M_boxDuration (Expiration): 2 weeksPurpose: We use Adobe Test & Target to implement A/B testing, Multivariate test on the website to test and learn in order to improve website user experienceFor more information about the data practices of Adobe Target, please visit their <a href="https://marketing.adobe.com/resources/help/en_US/target/?f=c_privacy" target="_blank">privacy policy</a>To opt out, please go <a href="https://marketing.adobe.com/resources/help/en_US/tnt/help/t_Adding_an_Opt-Out_Link.html" target="_blank">here</a> Cookie: Adara Name: Random, a unique string of characterDuration (Expiration): 2 yearsPurpose: ADARA provides digital advertising and analytics services for the benefit of business customers, giving them the ability to reach and understand Internet users and consumers who are most likely to be interested in their respective products and servicesTo opt out, please go <a href="https://adara.com/opt-out/" target="_blank">here</a> Cookie: SojernName: Random, a unique string of characterDuration (Expiration): 2 yearsPurpose: Sojern use cookies to make advertising more engaging to visitors. Some common applications of cookies are to select advertising based on what’s relevant to a visitorTo opt out, please go <a href="https://preferences-mgr.truste.com/?pid=sojern01&aid=sojern03&type=sojern_product" target="_blank">here</a> <h2>Functionality:</h2>Cookie: Session CookiesName: ASP.NET_SessionId, UserSettingsDuration (Expiration): Session CookiePurpose: These cookies enable us to keep track of the information that you have entered and the selections that you have made (e.g. city, dates, room type, etc.) as you move from page to page so that you don't have to enter the same information more than once. Cookie: Favorite Pages Name: Favorites-listDuration (Expiration): 365 daysPurpose: This cookie is used to store pages that has been marked as favorite by the visitor on our mobile site, in order to provide easy access to those pages in the site. Cookie: Hide Special Announcement Name: – Duration (Expiration): End of SessionPurpose: If the user closes the special announcement, this cookie is set to true. It prevents the special announcement from showing on any other pages. If the browser is closed and the user comes back to the site, the cookie will be expired and the special announcement will be shown again.<h2> </h2><h2>Targeting:</h2>Cookie: AddThisName: uid, dt, di, sshDuration (Expiration): –Purpose: These cookies are used by Addthis.com which collects information to customize the AddThis Button to your usage patterns.For more information read <a href="http://www.addthis.com/privacy/privacy-policy#.T9hyRBcti5J" target="_blank">Add This privacy</a> Cookie: Number Of VisitsName: EPi:NumberOfVisitsDuration (Expiration): Expires NEVERPurpose: This cookie is to provide more relevant content based on the amount of times that a customer has visited the site. <h2>For Analytics.js - Cookie Usage:</h2>The analytics.js JavaScript library is party of Universal Analytics and uses a single first-party cookie containing an anonymous identifier used to distinguish users. Cookie: Google AnalyticsName | Duration (Expiration) | Purpose: <ul><li>_ga | 2 years | Distinguish the current domain, start and end of a session, traffic source, unique visitors, number and time of previous visit and value of visitor-level custom variables.</li><li>_utma | 2 years from set/update | Used to distinguish users and sessions. The cookie is created when the javascript library executes and no existing _utma cookies exists. The cookie is updated every time data is sent to Google Analytics.</li><li>_utmb | 30 mins from set/update | Used to determine new sessions/visits. The cookie is created when the javascript library executes and no existing _utmb cookies exists. The cookie is updated every time data is sent to Google Analytics.</li><li>_utmc | End of browser session | Not used in ga.js. Set for interoperability with urchin.js. Historically, this cookie operated in conjunction with the _utmb cookie to determine whether the user was in a new session/visit.</li><li>_utmz | 6 months from set/update | Stores the traffic source or campaign that explains how the user reached your site. The cookie is created when the javascript library executes and is updated every time data is sent to Google Analytics.</li><li>_utmv | 2 years from set/update | Used to store visitor-level custom variable data. This cookie is created when a developer uses the _setCustomVar method with a visitor level custom variable. This cookie was also used for the deprecated _setVar method. The cookie is updated every time data is sent to Google Analytics.</li></ul> (* The “DURATION” refers to the cookie expiry date.) For Urchin.js – Cookie UsageHistorically, Google Analytics provided a JavaScript measurement library named urchin.js. When the newer ga.js library launched, developers were encouraged to migrate to the new library. For sites that have not completed the migration, urchin.js sets cookies identically to what is set in ga.js. Read the ga.js cookie usage section above for more details. How to change and delete cookiesTo enable or disable cookies, follow the instructions provided by your browser (usually located within the 'Help', 'Tools' or 'Edit' facility). Alternatively, an external resource is available at <a href="http://allaboutcookies.org/manage-cookies" target="_blank">All about cookies</a> providing specific information about cookies and how to manage them.