Effective Date of Privacy Policy: 27 October 2018
Updated: 01 Feb 2023
This Privacy Policy sets forth the principles that govern our treatment of personal data. We expect all employees and those with whom we share personal data to adhere to this Privacy Policy. Balmoral House is committed to protecting the information that our guests, prospective guests, patrons, employees, and suppliers have entrusted to us. This Privacy Policy applies to all personal data in any format or medium, relating to all guests, prospective guests, patrons, employees, suppliers, and others who do business with Balmoral House.
Application of This Policy
This Privacy Policy is for Newfoundland and applies to personal data collected, stored, disclosed, and/or processed by Balmoral House. This Privacy Policy applies to websites owned and operated by Balmoral House or other websites on which this Privacy Policy, or a link to this Privacy Policy, appears as well as activities at the Balmoral House Properties to the extent Balmoral House notifies you of such activities being subject to this Privacy Policy.
This Policy is based on the Personal Data Protection Act 2012 (“PDPA”) and all the associated regulations and guidelines, as may from time to time be issued by the Personal Data Protection Commission (“PDPC”).
By visiting or using the Balmoral House website, you agree to the terms of this Privacy Policy. Please review this Privacy Policy carefully before visiting or using our website, or otherwise providing us with any of your personal data.
Note to EU and Non-EU Residents
The Company respects all individuals’ privacy rights under all the laws that apply to it, all over the world. We work to comply with privacy laws, including, but not limited to, any right you may have if you live in or visit Canada, where our properties are located.
The Company voluntarily tries to accommodate privacy requests made by individuals. Each request is evaluated to determine whether it can be accommodated without violating legal obligations and without creating a risk to the security or integrity of the other information we hold.
For residents of the European Union (“EU”), European Economic Area (“EEA”), and Switzerland, the Company recognizes the legal privacy protections afforded to individuals located in the EEA, the EU, and Switzerland, with regard to personal data. For more information about this, please read the Notice to Residents of the EU, EEA, and Switzerland provided below.
Personal Data We Collect and Use
General Information
When you use the Internet, your computer may transmit certain information to the servers that host the websites you visit. The information may include the type of Internet browser you are using, the type of computer operating system you are using, your Internet Portal (IP) address, the pages you visited on our websites, and how you arrived at our websites. When you visit our websites, we collect this information, and we use this information to create a better user experience, to identify areas for improvement on our websites, to enhance the security of our systems, and to provide information on our special offers and promotions.
Cookies and Other Internet Technologies
When you visit our website, we may assign your computer one or more “cookies”. By accessing our website, you agree that we can place cookies on your device.
What Are Cookies?: A “cookie” is a small text file that a website can place on your computer to store your preferences. Cookies are not personally identifiable by themselves, but they can be linked to the personal data you provide to us.
How We Use Cookies: We may use cookies so that we can improve your online experience, including to detect your browser’s capabilities, to track ads we display to you, to store login and purchase information of your choice, to present advertising and other content on our website that is tailored to your web preferences and usage patterns, and to generate statistics on website usage.
How We Use Internet Technologies: In addition to cookies, we may also use other internet technologies such as web beacons, pixel tags, and other similar technologies to deliver or communicate with cookies and track your use of our website. We also may include web beacons in e-mail messages or newsletters to determine whether messages have been opened and acted upon, and how. The information we obtain in this manner enables us to customize the services we offer and measure the overall effectiveness of our online content, advertising campaigns, and the products and services we offer through our website. By accessing our website and agreeing to receive our e-mail messages or newsletters, you agree that we can use other Internet technologies such as those mentioned above on your device.
Your Control of Our use of Cookies: You have many choices on how to manage cookies on your device. Most web browsers allow some control of cookies through your browser settings. Generally, you may block or delete cookies from your system, or set your browser to prevent cookies from being placed on your devices if you do this, however, you may have to manually adjust preferences every time you visit our websites and it may not be possible to use the full functionality of our websites. To learn more about your ability to manage cookies, please consult the privacy features in your browser. Alternatively, you may opt-out of cookies and advertising related to the same by visiting the Network Advertising Initiative opt-out page: http://www.networkadvertising.org/choices.
How Third Parties Use Cookies and Other Internet Technologies: Our website may allow third parties to download cookies onto your device. Third parties, such as analytics firms and business partners (including Google) may use cookies and other technologies (including Google Analytics) to collect information about your online activities while you are on our website. This information may be used to measure usage of our website and personalize advertising content on our website. We do not have access to or control over cookies or other features these third parties may use, and the information practices of these third parties are not covered by this Privacy Policy. Please refer to the privacy policies of those third parties to better understand their activities and practices.
Google Analytics: We use features of Google Analytics in accordance with the How We Use Cookies section. For more details on how Google Analytics functions, please refer to Google’s Privacy Policy. According to its own policy, Google does not collect any personal data using Google Analytics. Nevertheless, if you do not want to use the remarketing feature from Google, you can disable it by changing the appropriate settings at http://www.google.com/settings/ads.
Personal Data
We may collect certain types of personal data. As used in this Policy, “personal data” means data, whether true or not, about an individual who can be identified: (a) from that data; or (b) from that data and other information to which the organization (in this case Balmoral House, and all the third parties of relevance mentioned in this Privacy Policy) has or is likely to have access. Personal data includes, among other things, your: name; street or mailing address; telephone number(s); email addresses; date of birth; gender; nationality; passport number, date and place of issue; NRIC number; driver’s license number and expiration; voice, photographs, images, and gaming activity; reservation information; dates of stay; travel history; guest and room preferences; purchases of products and services; payment information; credit card information; marketing preferences; preferred communication methods; reviews and opinions about Balmoral House (if they are identified or associated with you); frequent flyer or travel partner program affiliation and member numbers; hotel, airline and rental car packages booked; groups with which you are associated for reservations and group discounts; location (for location-based mobile applications); answers you provide to security questions (such as your mother’s maiden name, the name of your pet, etc.); information used to provide products or services; information needed to administer rewards or loyalty programs, including transaction and correspondence details; and any other types of information that you choose to provide to us or that we may collect about you through your transactions with Balmoral House Properties websites.
We may collect additional personal data about you that you knowingly and voluntarily provide in connection with certain activities at or transactions with Balmoral House or our websites, such as participation in certain meetings and events, participation in social media offerings (such as signing up through our Facebook pages), applications for employment, and liability claims. For example, if you apply for credit at Balmoral House or our websites, we may collect information to process your credit line request, including your identification number, bank account and other financial information, and employment information. The additional information that we collect depends on the nature of the activity or transaction or how you are interacting with our website.
We may also collect information that is not personally identifiable by itself but can be linked to the personal data you provide to us. Such information includes the type of Internet browser you are using, your device MAC address, the pages you visited on our websites, how you arrived at our websites (i.e., through a search engine or a referring website), etc.
Situations where we collect your information:
When you enroll in our News Letter, we may collect your name, title, and email address.
When you inform us of your application for credit extension, we may collect your credit information including your name, mailing address, email address, phone number, date of birth, credit score, employment information, financial information, including bank account and bank rating information, supporting your eligibility to receive credit, other lines of casino credit in your name, and other information you provide to us to assist us in making a determination concerning extending credit to you.
When you are at the Balmoral House property, we use closed-circuit television and other security systems to monitor other public or sensitive areas of our properties for safety and security, as well as, all areas as required by the applicable local regulatory authorities. Video surveillance cameras are used to protect us, our guests, and our employees. We monitor our surveillance cameras and may share surveillance footage with law enforcement and/or regulatory authorities.
When you complete an employment application, we may collect your name or aliases, current and previous, mailing address information, current and previous, email address, phone number, date of birth, employment history, credit history, education, training, and skills, including licenses and certificates, convictions for felonies or misdemeanors, proof of eligibility to work in the Canada, military service, and any other information provided in your employment application form.
When you make a reservation booking at the Balmoral House hotel, we may collect your personal data, whether it be through our websites, by phone, or in-person at one of our properties, to complete your reservation request. We also may need to collect information to comply with local laws, including your full name, nationality, and passport number. If you choose to provide it, we also may collect additional information from you, including your frequent flyer or travel partner program information.
When you check-in at the Balmoral House hotel, we may ask whether you wish to receive promotional and other marketing materials, including your interest in participating in contests, promotional offers, or using certain services we can provide to you, such as membership in our loyalty program. We also may send surveys to you to learn more about your stay and preferences. You may withdraw your consent to receive marketing and promotional materials at any time.
During your stay at the Balmoral House hotel, we record your itemized spending related to your reservation. This includes your room rate, other expenses billed to your room, food and beverage preferences, and other special requests. We collect and record this information to keep a record of your expenses and preferences during your stay and provide it to you upon check-out.
Other Sources of Data
Other parties may provide your information to us so that we can provide products and services and use your information for purposes listed in the How We May Use Your Information section. Some situations of such data sharing are set out below.
Vendors, Suppliers, and Others Doing Business with Us: We have strict rules in place to comply with the laws that apply to us. Before we do business with a third party, we take reasonable steps to make sure that they will prudently protect the information we share with each other, including your personal data they may collect or receive.
Third Parties Authorized By You: When someone else arranges for you to interact with our properties, they may provide us information so that we can provide you with products and/or services during your visit. For example, when your employer or a travel agent arranges for you to stay at one of our properties, they may provide us with the information listed above so that we can provide you with products and services.
Age Policy
Our websites are not intended for persons under the age of 21. If you are under the age of twenty-one (21) you may not use our website.
How We May Use Your Information
Your privacy is important to us. We collect and use or disclose the information we believe is necessary to our business, and to provide you with the products, services, and experiences you expect when you interact with us. When we collect and use your information, we take your privacy and security very seriously.
We collect personal data to deliver superior quality of service. We will use the information you provide to us for the purpose you provided it to us (e.g., to make a reservation, pay for a service, etc.), which is stated when information is collected. We may also use your information in other ways for our business purposes and to provide you with the products, services, and experiences you request and expect from us, including but not limited to the following purposes:
To fully respond to your questions, requests, or communications;
To verify your identity;
To process guest reservations and/or requests for information or services;
To provide you with personalized content on our website and to improve the content and the navigability of our website;
To improve and personalize the guest experience for you and others;
To develop new Balmoral House products and services;
To audit, research, and conduct analysis in order to maintain and improve our services and protect our guests and patrons;
To conduct statistical or demographic analysis, marketing and promotions planning and execution, market research and analysis, customer satisfaction and quality assurance surveys;
To consider your job application;
To ensure the technical functioning and security of our network;
To take steps to ensure and monitor safety and security and protection of your personal data, including working with third parties to help protect your information;
To comply with applicable laws and regulations, court orders or other legal processes or other legal requirements of any governmental authorities, and to assist our contracting parties to comply with the same;
To defend and protect the rights or property of Balmoral House, its employees, and its guests and patrons; and/or
To facilitate a change in the business structure or ownership of Balmoral House or its assets, in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of Balmoral House’ business, assets, or stock, including any bankruptcy or similar proceedings
To respond to exceptional circumstances, such as a national emergency, security concern, or other situation in which Balmoral House deems disclosure of your information as prudent.
If you have ceased to be our customer or client and have canceled your account or membership, we will not send you marketing materials or share your personal data with unrelated third parties. However, we may still retain your records and use your information for legal and/or business purposes, including for compliance with any applicable laws.
Who We Share Information With
We may share information about you with the third parties (whether located within or outside of Canada) as indicated below for the purposes set out in the How We May Use Your Information section.
Our Balmoral House affiliates;
Balmoral House’ Agents and Service Providers who help us to provide some of our products and services or organize events (e.g., maintenance, IT and telecommunications support, website hosting and operations, distribution of newsletters and marketing materials, analysis, audit, payments, insurance, promotions, marketing, development, credit, reservations, security, to operate any of our businesses or our website). For example, from time to time we may run promotions or marketing efforts, such as contests, sweepstakes, and/or giveaways with third parties. If you choose to participate in any such promotions, then any personal data you provide in order to participate may be shared with those third parties and be subject to their privacy policies. Unless we tell you differently or as described elsewhere in this Privacy Policy, our agents are expected not to have the right to use your information beyond what is needed to assist us;
Governmental authorities, regulatory agencies, statutory boards, government officials, law enforcement authorities, industry associations, legal process participants such as our legal advisers, courts, or other alternative dispute forums; and/or
Any third party in connection with any proposed or actual changes in our business structure or ownership, for example, in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of Balmoral House business, assets, or stock (including any bankruptcy or similar proceedings).
Sale of Information: In the future, we may sell some or all of our assets. In such transactions, customer information is generally one of the transferred business assets. In the event of a sale of Balmoral House assets including customer information, we will require the buyers to honor our Privacy Policy or provide you with notice and an option to limit sharing of your information.
International Transfers of Information: We operate our website in Canada and we may transfer personal data to Balmoral House Properties and our affiliates in the United States. Please note that the United States currently is not on the list of countries that the European Commission considers adequate regarding the protection of personal data. Regardless, we have taken steps to ensure that appropriate levels of protection necessary to maintain the security and integrity of your personal data are in place and that any transferred data is processed in accordance with the PDPA and any other applicable law.
We may share anonymous or aggregate information among all Balmoral House entities and with third parties, including advertisers, investors, and partners. Aggregate or anonymous information does not contain any personal data, and accordingly, its use and disclosure are not subject to the terms of this Privacy Policy.
Note on third-party websites – Our website may contain links to third-party websites, which are not controlled by us and which are not covered by this Privacy Policy. You are responsible for reviewing the privacy policies of all such third parties, and we recommend that you read those policies very carefully before disclosing your personal data to any third party, whether directly or indirectly.
How We Protect Your Personal Data
We strive to take appropriate security measures to help safeguard your personal data from unauthorized access and disclosure. For example, only authorized employees are allowed to access personal data, and they may only access it for permitted business functions. We also use technology to protect your information, including encrypting sensitive personal data that is transferred to or from our systems and using firewalls to help prevent unauthorized persons from accessing information. If you have an online account with us, your account is also protected by a password for your privacy and security, and you must prevent unauthorized access to your account and personal data by selecting and protecting your password appropriately, limiting access to your devices, and by signing off after you have finished accessing your account.
While we cannot guarantee that loss, misuse, or alteration of information will never occur, we use reasonable efforts to prevent it. Please keep in mind that no method of storage or transmission over the Internet is completely secure, so your use of our products and services and the provision of information to us are at your own risk.
Please be aware that our websites may contain links to other sites on the Internet that are owned and operated by third parties. The information practices of those websites linked to our websites are not covered by this Privacy Policy. We are not responsible for the privacy policies of websites to which our website links. If you provide any information to such third parties, different rules regarding the collection and use of your personal data may apply. We strongly suggest you review such a third party’s privacy policies before providing any data to them.
Your Choices Regarding Your Information
Please note that subject to the PDPA, not all information that we have collected may be available for review.
To Withdraw Consent or Object: You may request for us to cease to process your personal data at any time for any purpose(s) by submitting the appropriate withdrawal of consent form which can be found at http://www.balmoralhouse.com. Alternatively, if you have provided us with your email address and you would like to stop receiving marketing emails from us, you may click on the unsubscribe link at the bottom of any of our email communications. Please note that if you withdraw or decline your consent for a limited purpose, such as for marketing or a specific category of marketing, we may still contact you or use your information for other purposes for which you have not withdrawn your consent and such personal data may still be shared, as permitted under the PDPA and other applicable law.
Note To Residents of the EU, EEA, and Switzerland
If you reside or otherwise find yourself in the European Economic Area (“EEA”), European Union (“EU”), or Switzerland, we are committed to respecting your rights as a data subject under the applicable laws of these countries. For all personal data that we have about you, please note the following:
Automated Decision-making: We may use automated decision-making to determine whether job applicants meet the required qualifications. You have the right to have a human involved in this process, to express your point of view, and to contest the decision. You may do so by using the method in the Contact Us section below.
Data Portability, Imposing Restrictions on Data Processing, Data Erasure: If you would like to request that we provide a copy of your information to you or restrict processing of your information or erase it, please contact us using the method in the Contact Us section below.
Responding to Requests: Each request to access, correct, restrict processing, erase, or provide a copy of data will be evaluated to determine whether the requested change meets legal regulatory requirements and does not risk making our other data less secure or changing our other data. Please note that we will require you to provide us with proof of identity and address before responding to your requests to exercise such rights.
Complaints to Supervisory Authority: You have the right to lodge a complaint with a supervisory authority of the European Union or European Economic Area according to that authority’s rules and procedures.
Changes to this Privacy Policy
We reserve the right to modify or change this Privacy Policy at any time. The Effective Date, as stated above, indicates the last time this policy was materially revised. When we make a material change to this Privacy Policy, we will inform you by posting a prominent notice on the home page of our website or changing the date on this page noting when the Privacy Policy was last updated. We encourage you to review this page periodically to understand our policy regarding the collection and use of your personal data.
Your continued use of our website and acceptance of our services at Balmoral House after any changes to this Privacy Policy constitutes your consent to any such changes, to the extent such consent is not otherwise provided.
Contact Us
For questions regarding this Privacy policy or if you have a privacy concern or questions about how your personal data is used, please contact us at info@BalmoralHouse.com.