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PRIVACY

Introduction

Salt Hotels, LLC (referred to herein as “Salt Hotels”, “we”, “our” or “us”), recognize the importance of protecting personal data we may collect from visitors and any other individual or entity (“Users”, “you”, or “your”) who visit our web sites. This Privacy Policy applies to data collection by Salt Hotels when you visit or stay as a guest at one of our properties, and shall apply to your use of the website, www.salthotels.com, www.saltsupplystore.com, and other Salt Hotels-related sites, apps, communications, capabilities and services (“Services”) accessible on or by any top-level Salt Hotels domain owned by us (each, a “Site” and collectively the “Sites”), but excluding services that state that they are offered under a different privacy policy.

Our Privacy Policy explains: (1) what information we collect; (2) why we collect it; (3) how we use that information; (4) how we may share it; and (5) the choices we offer, including how to access and update information. Specifically, our Privacy Policy covers the following topics:

  1. When This Privacy Policy Applies
  2. Information We Collect
  3. How We Use Information We Collect
  4. Our Legal Basis for Collecting Personal Data
  5. Information We Share
  6. Your Failure to Provide Personal Data
  7. Our Retention of Your Personal Data
  8. Your Choices and Accessing, Updating or Deleting Your Personal Data
  9. Our Opt-in/Out-out Policy
  10. Social Media Platforms and Websites
  11. Third Party Links
  12. International Transfer
  13. How We Protect Personal Data
  14. Children
  15. Direct Marketing and “Do Not Track” Signals
  16. Changes to Our Website Privacy Policy
  17. How to Contact Us

Please familiarize yourself with our privacy practices and let us know if you have any questions. By using the Sites, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, please do not use the Sites.

Irrespective of which country you live in, you authorize us to transfer, store, and use your information in the United States, and any other country where we operate. In some of these countries, the privacy and data protection laws and rules regarding when government authorities may access data may vary from those in the country where you live. Learn more about our data transfer operations in the “International Transfer” section below. If you do not agree to the transfer, storage and use of your information in the United States, and any other country where we operate, please do not use the Sites or Services.

If you have any questions or comments about this Privacy Policy, please submit a request to privacy@salthotels.com.

When this Privacy Policy Applies

Our Privacy Policy applies to all of the Services offered by Salt Hotels, but excludes services that have separate privacy policies that do not incorporate this Privacy Policy.

Our Privacy Policy does not apply to services offered by other companies or individuals, including products or sites that may be displayed to you, or other sites linked from our services. Our Privacy Policy does not cover the information practices of other companies and organizations who advertise our services, and who may use cookies, pixel tags and other technologies to serve and offer relevant ads.

Information We Collect

We collect information, including personal data, to provide better Services to all our Users. We use the term “Personal Data” to refer to any information that identifies or can be used to identify you. Common examples of personal data include: full name, home address, email address, date of birth, digital identity, such as a login name or handle, information about your device, and certain metadata.

“Sensitive Personal Data” refers to a smaller subset of personal data which is considered more sensitive to the individual, such as race and ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic or biometric information, physical or mental health information, medical insurance data, or sexual orientation. Salt Hotels does not collect or use Sensitive Personal Data and asks that you do not provide Sensitive Personal Data to us.

We collect Personal Data in the following ways:

  1. Information You Give to Us

You may choose to provide us with personal data about yourself, including your name, billing address, email, phone number, zip or postal code, and user name and password, location information, birthdate, booking, stay and purchase history by completing forms on our website. In order to complete a reservation, an online credit card transaction may be required. During this process, you may provide us with the first and last name of the payment card owner, credit card billing address, payment card number, payment card expiration date, card verification value (“CVV”), shipping address, phone number and email.

When using our Services, you may elect to provide us with location and address information. You may also provide us with Personal Data about yourself when you report a problem or have a question about our Services.

The Sites offer interactive and social features that permit you to submit content and communicate with other users. You may provide personal data to us when you post information in these interactive and social features. Please note that your postings in these areas of the Sites may be publicly accessible or accessible to other users.

Please note that if you do not provide us with Personal Data, your ability to use certain aspects of our Services may be limited.

  1. Information We Obtain from Your Use of Our Services

We collect certain information automatically, such as your operating system version, browser type, and internet service provider. When you use our Site, we automatically collect and store this information in service logs. This includes: details of how you used our Site; Internet protocol address; and cookies that uniquely identify your browser.  We may also collect and process information about your actual location. The information we collect automatically is statistical data and may or may not include Personal Data, but we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties.

  1. Cookies and Similar Technologies

We and our partners use various technologies to collect and store information when you visit our Site, and this may include using cookies or similar technologies to identify your browser or device. We also use these technologies to collect and store information when you interact with services from our partners, such as advertising services. Our third party advertising and analytics partners include Google and similar partners.

The technologies we use for this automatic data collection may include:

Cookies. A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our services.  

Web Beacons. Pages of our Sites 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, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

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 the Sites, what type of content is popular, what type of visitors in the aggregate are interested in particular kinds of content on the Sites.

How We Use Information We Collect

We use your personal data in ways that are compatible with the purposes for which it was collected or authorized by you, including for the following purposes:

  1. To inform you about Services you request, including:
  2. To facilitate reservations, payment, send administrative information, confirmations or pre-arrival messages;
  3. To complete your reservation and stay, for example, to process your payment, ensure that your room is available and provide you with related customer service;
  4. To support our electronic receipt program;
  5. To manage our contractual relationship with you;
  6. To authorize access to our Sites and Services;
  7. To provide you with Services and Products, including to customize your experience according to your personal preferences and to present offers tailored to your personal preferences;
  8. To offer and administer programs;
  9. To administer content, promotion, sweepstakes, surveys, voting polls or other Site features;
  10. To communicate about, and administer your participation in, special programs and offers, as well as periodic customer satisfaction, market research and quality assurance surveys, and to deliver pertinent emails;
  11. To improve our customer service;
  12. To respond to and support users regarding their use of the Sites and Services;
  13. To comply with all applicable legal requirements.
  14. To investigate possible fraud or other violations of this Privacy Policy and/or attempts to harm our guests or employees.

We use the information we collect from our Sites to provide, maintain, and improve them, to develop new Services, and to protect our Company and our users.

We use information collected from cookies and other technologies, to improve your user experience and the overall quality of our Services. We may use your personal information to see which web pages you visit at our Site, which web site you visited before coming to our Site, and where you go after you leave our Site. We can then develop statistics that help us understand how our visitors use our Site and how to improve it.  We may also use the information we obtain about you in other ways for which we provide specific notice at the time of collection.

We will ask for your consent before using information for a purpose other than those set out in this Privacy Policy.

Our Legal Basis for Collecting Personal Data

Whenever we collect Personal Data from you, we may do so on the following legal bases:

  1. Your consent to such collection and use;
  2. Out of necessity for the performance of an agreement between us and you, such as your agreement to use our Services or your request for Services, such as lodging;
  3. Our legitimate business interest, including but not limited to the following circumstances where collecting or using Personal Data is necessary for:
  4. Intra-organization transfers for client data for administrative purposes;
  5. Product development and enhancement, where the processing enables Salt Hotels to enhance, modify, personalize, or otherwise improve our Services and communications for the benefit of our users, and to better understand how people interact with our Sites;
  6. Communications and marketing, including processing data for direct marketing purposes, and subject to your opt-in for these purposes, and to determine the effectiveness of our promotional campaigns and advertising;
  7. Fraud detection and prevention;
  8. Enhancement of our cybersecurity, including improving the security of our network and information systems; and
  9. General business operations and diligence;

Provided that, in each circumstance, we will weigh the necessity of our processing for the purpose against your privacy and confidentiality interests, including taking into account your reasonable expectations, the impact of processing, and any safeguards which are or could be put in place. In all circumstances, we will limit such processing for our legitimate business interest to what is necessary for its purposes.

Information We Share

We do not share personal information with companies, organizations and individuals outside of the Organization unless one of the following circumstances applies:

  • Strategic Business Partners. We disclose Personal Data and other Data with select Strategic Business Partners who provide goods, services and offers that enhance your experience at our properties or that we believe will be of interest to you. By sharing data with these Strategic Business Partners, we are able to make personalized services and unique travel experiences available to you. For example, this sharing enables spa, restaurant, health club, concierge and other outlets at our properties to provide you with services. This sharing also enables us to provide you with a single source for purchasing packages that include travel-related services, such as airline tickets, rental cars and vacation packages.
  • For external processing. We provide personal information to our affiliates or other trusted businesses or partners to process it for us, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures. These third parties include payment and payroll processors, such as financial institutions and their vendors and contractors that process transactions. It is our policy to only share Personal Data with contractors, service providers and other third parties who are bound by contractual obligations to keep Personal Data confidential and use it only for the purposes for which we disclose it to them.  Under certain circumstances, you may avoid having us share your information with our business partners and vendors by not granting us permission to share your information.  Not granting us permission to share your information with our business partners or vendors may limit your access to their services through the Sites. We do not share personal information with third parties for their own marketing purposes.
  • For Legal Reasons. We will share Personal Data with companies, organizations or individuals outside of Salt Hotels if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
  • meet any applicable law, regulation, legal process or enforceable governmental request.
  • enforce applicable Terms of Use, including investigation of potential violations.
  • detect, prevent, or otherwise address fraud, security or technical issues.
  • protect against harm to the rights, property or safety of Salt Hotels, our Users or the public as required or permitted by law.

We attempt to notify Users about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

  • Business Transfers. If we establish a new related entity, are acquired by or merged with another organization, or if substantially all of our assets are transferred to another organization, Personal Data about our users is often a transferred business asset.  In the event that Salt Hotels itself or substantially all of our assets are acquired, Personal Data about our users may be one of the transferred assets.
  • Aggregate Site Use Information. We may share aggregate and anonymized/pseudonymized Personal Data to third parties in order to promote or describe use of the Sites, for research, marketing, advertising, or similar purposes.

Your Failure to Provide Personal Data

Your provision of Personal Data is required in order to use certain parts of our Services.  If you fail to provide such Personal Data, you may not be able to access and use our Services, or parts of our Services.  

Our Retention of Your Personal Data

We may retain your Personal Data for a period of time consistent with the original purpose for collection.  For example, we keep your Personal Data for no longer than reasonably necessary for your use of our programs and Services and for a reasonable period of time afterward. We also may retain your Personal Data during the period of time needed for us to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements.

Your Choices and Accessing, Updating or Deleting Your Personal Data

Whenever you use our Services, we aim to provide you with choices about how we use your personal data. We also aim to provide you with access to your Personal Data. If that information is wrong, we strive to give you ways to update it quickly or to delete it – unless we have to keep that information for legitimate business or legal purposes. Subject to applicable law, you may obtain a copy of personal information we maintain about you or you may update or correct inaccuracies in that information by contacting us. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to the information. In addition, if you believe that personal information we maintain about you is inaccurate, subject to applicable law, you may have the right to request that we correct or amend the information by contacting us as indicated in the How to Contact Us section below.

  • European Users’ Rights With Respect to Personal Data

Some data protection laws, including the European Union’s General Data Protection Regulation (“GDPR”), corresponding legislation in Switzerland and in the United Kingdom, and some U.S. state laws, provide you with certain rights in connection with Personal Data you have shared with us. If you are resident in the European Economic Area or another jurisdiction which conveys these rights to you, you may have the following rights:

  1. The right to be informed. You are entitled to be informed of the use of your Personal Data.  This Privacy Policy provides such information to you.
  2. The right of access. You have the right to request a copy of your Personal Data which we hold about you.
  3. The right of correction: You have the right to request correction or changes of your Personal Data if it is found to be inaccurate or out of date.  
  4. The right to be forgotten: You have the right to request us, at any time, to delete your Personal Data from our servers and to erase your Personal Data when it is no longer necessary for us to retain such data.  Note, however, that deletion of your Personal Data may impact your ability to use some of our Services.
  5. The right to object (opt-out): You have the right to opt-out of certain uses of your Personal Data, such as direct marketing, at any time.  
  6. The right to data portability: You have the right to a “portable” copy of your Personal Data that you have submitted to us.  Generally, this means your right to request that we move, copy or transmit your Personal Data stored on our servers / IT environment to another service provider’s servers / IT environment.
  7. The right to refuse to be subjected to automated decision making, including profiling: You have the right not to be subject to a decision and insist on human intervention if the decision is based on automated processing and produces a legal effect or a similarly significant effect on you.
  8. The right to lodge a complaint with a supervisory authority.

You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here:  http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.  

If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law. To make these requests, you may contact us using the contact information below, and we will consider your request in accordance with applicable laws. For your protection, we may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches your email address that we have on file.  If we no longer need to process Personal Data about you in order to provide our Services, we will not maintain, acquire or process additional information in order to identify you for the purpose of responding to your request.

In some cases our ability to uphold these rights for you may depend upon our obligations to process personal information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the Services you have requested. Where this is the case, we will inform you of specific details in response to your request.

  • Changing or Deleting Your Information

You may update or correct information about yourself by emailing us at privacy@salthotels.com.  If you completely delete all such information, then your account may become deactivated.  We may retain an archived copy of your records as required by law, to comply with our legal obligations, to resolve disputes, to enforce our agreements or for other legitimate business purposes.  

We may contact you to request that you update your Personal Data on a regular basis to ensure its integrity for the purposes of ongoing data management.

  • Our Opt-in/Opt-out Policy

By providing an email address on the Salt Hotels Sites, you agree that we may contact you in the event of a change in this Privacy Policy, to provide you with any service related notices, or to provide you with information about our events, invitations, or related educational information.

For purposes of this Privacy Policy, “opt-in” is generally defined as any affirmative action by a user to submit or receive information, as the case may be.

We currently provide the following opt-out opportunities:

  1. AT ANY TIME, YOU CAN FOLLOW A LINK PROVIDED IN OFFERS, NEWSLETTERS OR OTHER EMAIL MESSAGES (EXCEPT FOR E-COMMERCE CONFIRMATION OR SERVICE NOTICE EMAILS) RECEIVED FROM US TO UNSUBSCRIBE FROM THE SERVICE.    
  2. AT ANY TIME, YOU CAN CONTACT US THROUGH PRIVACY@SALTHOTELS.COM OR THE ADDRESS OR TELEPHONE NUMBER PROVIDED BELOW TO UNSUBSCRIBE FROM THE SERVICE AND OPT-OUT OF OUR RIGHT PER YOUR CONSENT UNDER THE TERMS OF THIS PRIVACY POLICY TO SHARE YOUR PERSONAL DATA.  

Notwithstanding anything else in this Privacy Policy, please note that we always reserve the right to contact you in the event of a change in this Privacy Policy, or to provide you with any service related notices.

Social Media Platforms and Websites

Any information, communications or material of any type or nature that you submit to our Websites (including, but not limited to any Salt Hotels website contained on a social media platform or website such as Facebook or Twitter) by email, posting, messaging, uploading, downloading, or otherwise (collectively, a “Submission”), is done at your own risk and without any expectation of privacy.

Salt Hotels is not responsible for any content or Submissions contained on such sites and platforms. By visiting any Salt Hotels website that is contained on a social media platform or website, you are representing and warranting to Salt Hotels that you have reviewed the applicable privacy policy and terms of use of that platform or website and that you will abide by all such provisions contained therein.

Additionally, in the event that Salt Hotels offers a message board or any other interactive or social-type feature on a website administered directly by Salt Hotels, please be aware that these platforms may allow you to publicly post and share information with other users. Although Salt Hotels may take certain precautions to protect those who use these areas of a Salt Hotels website, we warn against giving you should not give out any personal data in such public forums as we cannot guarantee the privacy that information will not be private and safety of these areas and may not be monitored and is not guaranteed, and we therefore cannot be responsible for any misused information you choose to post. Your use of these features is fully at your own risk.

Third Party Links

The Sites may contain links to webpages operated by parties other than Salt Hotels. We do not control such websites and are not responsible for their contents or the privacy policies or other practices of such websites. Our inclusion of links to such websites does not imply any endorsement of the material on such websites or any association with their operators. Further, it is up to the User to take precautions to ensure that whatever links the User selects or software the User downloads (whether from this Site or other websites) is free of such items as viruses, worms, trojan horses, defects and other items of a destructive nature. These websites and services may have their own privacy policies, which the User will be subject to upon linking to the third party's website. Salt Hotels strongly recommends that each User review the third party's terms and policies

International Transfer

We are committed to complying with applicable laws, regulations and mandatory government standards regarding the protection of Personal Data.  

Since we are a global organization, Personal Data and any additional information submitted may be used globally in connection with employment, business processes within Salt Hotels, or communicating with our clients. Therefore, Personal Data may be transferred to other Salt Hotels entities worldwide, where it will be processed in accordance with this Privacy Policy and laws that are applicable in each country. Countries where we process data may have laws which are different, and potentially not as protective, as the laws of your own country.

If we transfer your Personal Data out of your jurisdiction, we will implement suitable safeguards and rely on legally-provided mechanisms to lawfully transfer data across borders to ensure that your Personal Data is protected.

For EU and Swiss Individuals: Your Rights under Privacy Shield

Salt Hotels complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries, the United Kingdom and Switzerland transferred to the United States pursuant to Privacy Shield. Salt Hotels has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/    

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Salt Hotels is subject to the regulatory and enforcement powers of the U.S. Federal Trade Commission.

Pursuant to the Privacy Shield Frameworks, EU, UK and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to privacy@salthotels.com. If requested to remove data, we will respond within a reasonable timeframe.

We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to privacy@salthotels.com

In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Salt Hotels’ accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Salt Hotels remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Principles, unless Salt Hotels proves that it is not responsible for the event giving rise to the damage.

In compliance with the Privacy Shield Principles, Salt Hotels commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union, United Kingdom and Swiss individuals with Privacy Shield inquiries or complaints should first contact Salt Hotels by email at privacy@salthotels.com

Salt Hotels has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

How We Protect Personal Data

Salt Hotels maintains administrative, technical and physical safeguards designed to protect the User's Personal Data and information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, taking into account technological reality, cost, the scope, context and purposes of processing weighted against the severity and likelihood that the processing could threaten individual rights and freedoms. For example, we use commercially reasonable security measures such as encryption, firewalls, and Secure Socket Layer software (SSL) or hypertext transfer protocol secure (HTTPS) to protect Personal Data.  

If Salt Hotels collects account information for payment or credit, Salt Hotels will use the information only to complete the task for which the account information was offered.

Children

The Site is not intended for use by children.  We do not intentionally gather Personal Data about visitors who are under the age of 16.  If a child has provided us with Personal Data, a parent or guardian of that child may contact us to have the information deleted from our records. If you believe that we might have any information from a child under age 16, please contact us at privacy@salthotels.com. If we learn that we have inadvertently collected the personal information of a child under 16, or equivalent minimum age depending on jurisdiction, we will take steps to delete the information as soon as possible.  

Direct Marketing and “Do Not Track” Signals

Salt Hotels does not track its users over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals. However, some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser may include controls to block and delete cookies, web beacons and similar technologies, to allow you to opt out of data collection through those technologies.

California residents are entitled to contact us to request information about whether we have disclosed personal information to third parties for the third parties’ direct marketing purposes.  We do not disclose personal information to third parties for the third parties’ direct marketing purposes. California users may request further information about our compliance with this law by e-mailing us at the address listed in the “How to Contact Us” section.

Changes to this Privacy Policy

Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent. We will post any changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain Services or programs, email notification).

How to Contact Us

If you have any specific questions about this Privacy Policy, you can contact us via email or by writing to us at the address below:

Send e-mail to: privacy@salthotels.com

Send mail to our address:

Salt Hotels
Attn: Privacy Policy Inquiry
353 Commercial St.
Provincetown, Massachusetts 02657
U.S.A.

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