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PRIVACY POLICY
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Privacy Policy

At Crown & Champa Resorts "CCR", we strive to deliver outstanding products, services, and experiences. We value your business and, more importantly, your loyalty. We recognize that privacy is an important issue. We have developed this Privacy Policy (this "Policy") to explain the practices of CCR regarding the personal information we collect when you visit this site. Some jurisdictions also require notice concerning other means of collecting personal information; for those jurisdictions, this Policy also explains our practices regarding personal information obtained from sources other than our websites, such as written or verbal communications or information collected when you visit one of our properties.

Please read this Policy carefully before submitting personal information about you to us. Also, please note that this Policy does not apply to our processing of personal information on behalf of and subject to the instructions of third parties such as airlines, and other service providers, companies that organize or offer packaged travel arrangements.

Personal Information We Collect
At every touch point or guest interaction, and in conducting every aspect of our business, we may collect personal information. This personal information may include: your name and contact information, including physical address, email address and telephone number; information related to your reservation, stay or visit to a property; participation in a membership or loyalty program; purchase of products or services; personal characteristics, including date of birth, gender and nationality; passport number and date and place of issue; travel history; payment information; guest preferences; marketing preferences; dates of stay; preferred communication methods; business name, title and address; method of payment; credit card details, including the three or four digit CVV code; amount of charges for stays at properties; products and services received; reviews and opinions about our properties (if they are identified or associated with you); frequent flyer or travel partner program affiliation and member number; hotel and airline packages booked; groups with which you are associated for stays at hotels; information needed to provide products or services or administer the Loyalty Program, including transaction and correspondence details; information provided on membership and account applications; information maintained in individual customer profiles; and other types of information that you choose to provide to us. We may also record details on joint travellers, including their names and frequent flyer numbers.

In addition we collect other personal information in certain cases, such as:

Loyalty Program: When you enroll in our Loyalty Program, we will also ask you to indicate whether you are at least 18 years old, and we will record an Loyalty Program number and password for you. When you manage your profile online, you have the opportunity to provide additional information about your preferred airline partners and your loyalty program account numbers with them, your room type preferences, your language preferences, your credit card account(s), your preferences for receiving news, offers and information from us, and to create a User ID and password. Also, we may ask for additional specific account information such as corporate account number, group or convention code or travel agent number.

Surveys: We may request demographic data or other personal information in customer surveys.

On-site Collection: Local laws may require that we collect additional personal information during registration / check-in at our properties. We also may use closed circuit television and other security measures at our properties that may capture or record images of guests and visitors in public areas. We also may collect additional personal information in connection with on-site services, such as concierge services, health clubs, spas, activities, child care services, and equipment rental.

Event Profiles: If you choose to create an online profile for meeting and event planning (e.g., weddings), we record meeting and event specifications, the date of the event, number of guests, details of the guest rooms, and, for corporate events, information on your organization (name, annual budget, number of sponsored events per year).

Social Media: If you choose to participate in CCR sponsored social media activities or offerings, we may collect certain information from your social media account with your permission, such as location, check-ins, activities, interests, photos, status updates and friend list.

Forward-to-a-Friend: From time to time, this site may offer a feature that allows you to send an electronic postcard or otherwise share a message with a friend. If you choose to do so, we will ask you for the recipient's name and email address, along with the text of any message you choose to include, or you may be able to use a pre-populated message. By using this feature, you warrant that you are entitled to use and provide us with the recipient's name and email address for this purpose.

Employment Applications: If you choose to apply online for employment with CCR, you will also have the opportunity to send your resume in electronic form, information on education and employment history, desired salary scale, working permits, and any other information you feel is relevant to your application. If you apply for employment online, any information about you which is obtained by us during the application process may be retained by us for purposes of considering your application for employment, as well as for more general management and research purposes.

Use of Personal Information Collected About You
We use your personal information to provide the services you request from CCR, or which are part of a program you have joined or a purchase you have made, such as to facilitate: reservations, the purchase of a vacation package purchases of hotel products (including online purchases from our sites, the booking of airfares, membership in the Loyalty Program, and other transactions. We also use the personal information to provide you with information about meeting and event planning and access to specific account information for administrative purposes. In addition, we may use the information to: improve CCR services; provide you with the expected level of hospitality; ensure our site, products and services are of interest to you; and to process enrollments and applications. We also use the information to provide or offer you newsletters, promotions and featured specials, and to conduct surveys, sweepstakes, prize draws, and other contests online and via email, telephone, mobile / text messaging (including SMS and MMS) and postal mail.

How We Share Personal Information
As a regional Company, we endeavor to provide you with the same level of service that you have come to expect at another CCR. To provide this service, we may share your personal information with other members of the CCR, managed hotels or service providers that may be located in countries outside of your own. Although the data protection laws of these various countries may not be as comprehensive as those in your own country, CCR will take appropriate steps to ensure that your personal information is handled as described in this Policy.

CCR Portfolio: We may share personal information with other companies within the CCR Portfolio that may jointly use the personal information for the purposes described above. CCR is the party responsible for the management of the jointly used personal information.

Managed Hotels: We may share personal information with owners and operators of hotels that we manage but do not own in order to provide you with services. In addition, when we cease managing a hotel that we do not own, we may provide the hotel's owner with limited information about past or future guests of that hotel.

Electronic Billing Program: If you participate in the "eFolio program", billing information will be shared with the credit card provider and if you use a corporate credit card, possibly, your employer.

Group Events or Meetings: If you visit CCR as part of a group event or meeting, information collected for meeting and event planning may be shared with the organizers of those meetings and events, and, where appropriate, guests who organize or participate in the meeting or event.

Business Partners: From time to time we may partner with other companies to provide products or services and may share your information with our business partners to provide those products or services to you. For example, we also may co-sponsor promotions, sweepstakes, prize draws, competitions or contests with other companies or we may provide prizes for sweepstakes and contests sponsored by other companies. If you enter one of these sweepstakes or contests, we may share your information with our co-sponsor or the third-party sponsor. If you are an Loyalty Program member, we may share your personal information with our business partners in order to credit you with mileage or other benefits earned through your participation in the Loyalty Program.

Onsite Services: We may share personal information with providers of onsite services that provide services such as concierge services, spa treatments, golf, or dining experiences.

Service Providers: We rely on service providers to provide certain products and services, such as to facilitate administrative functions and information technology operations, credit card billing, reservations services, administering the Loyalty Program providing services in connection with our websites, including airline packages; communicating news and delivering promotional and transactional materials via email and direct mail; processing credit card transactions, data hygiene and enhancement services; professional services such as accounting, auditing and legal advice; investigating accident reports; processing insurance claims; and administering sweepstakes, prize draws, competitions and customer surveys. CCR will disclose personal information to service providers as appropriate.

Business Transactions: As we develop our business, we might sell, buy, restructure or reorganize businesses or assets. In the event of a merger, consolidation, sale, liquidation or transfer of assets, CCR may, in its sole and absolute discretion, transfer, sell or assign information collected, including without limitation, non-personal information and personal information, to one or more affiliated or unaffiliated third parties.

Other: In addition, CCR may disclose personal information, with or without prior notice to you, in order to: (i) comply with applicable laws, (ii) respond to governmental inquiries or requests from public authorities, (iii) comply with valid legal process, (iv) protect the rights, privacy, safety or property of CCR, site visitors, guests, employees or the public, (v) permit us to pursue available remedies or limit the damages that we may sustain, (vi) enforce our websites' terms and conditions, and (vii) respond to an emergency.

Cookies and Other Technologies
When you visit and interact with this site, CCR and third parties with whom CCR has contracted to provide services to CCR, may collect non-personal information (for example, a catalog of the site pages you visit).

Our Collection and Use of Non-Personal Information
As with many other sites, our site may use "cookies" or other technologies to help us deliver content specific to your interests, to process your reservations or requests, and/or to analyze your visiting patterns. Cookies, by themselves, cannot be used to disclose your individual identity. This information identifies your browser, but not you, to our servers when you visit our site. If you want to remove or block cookies at any time from your computer, you can update your browser settings (consult your browser's "help" menu to learn how to delete or block cookies).

We also may collect data by using "pixel tags," "web beacons," "clear GIFs" or similar means (collectively, "pixel tags") that allow us to know when you visit our site and to understand how you interact with our emails or advertisements. Through pixel tags, we obtain non-personal information or aggregate information (i.e., the domain name, the areas of the site you visit, your operating system, your browser version, and the URL you came from) which can be used to enhance your online experience and understand traffic patterns.

Because non-personal information does not personally identify you, we may use or disclose such information for any purpose. In some instances, we may combine non-personal information with personal information (such as embedding email addresses in cookies). If we do combine any non-personal information with personal information, the combined information will be treated by us as personal information in accordance with this Policy.

Our Vendors' and Partners' Collection and Use of Non-Personal Information
We also work with vendors and other partners to help deliver online and mobile advertisements for our brands that we think may be of interest to you. Many of these advertisements are not targeted to you, but rather are placed on pages where we anticipate our target audience will visit frequently.

Our vendors and other partners also may use cookies, pixel tags and other technologies to perform services for us. CCR does not control the use of this technology or the resulting information and is not responsible for any actions or policies of such third parties. These vendors and other partners include websites, online and mobile advertising networks and similar advertising service providers, and content networks. These vendors and other partners may record which ads your browser has seen and which site pages you may have been viewing when the ads were delivered.

Some of our advertisements delivered for us by these vendors and other partners may be based on your online behaviors (e.g., on CCR sites and other third party sites), your search activity, or your general geographic location (such as whether your Wi-Fi network indicates that you are in an airport). These ads may appear on our own sites or on third-party websites. You may also see advertisements for third parties on other websites based on your visits to CCR sites and other sites.

Also, if you search for a hotel reservation on a CCR site, you may see an advertisement from a third party for a related or similar offer to that for which you were searching on the CCR site.

For example, if you have visited the home page or the booking page for one of our properties but not actually booked a room, or if you have searched for a specific term (such as location or dates of stay), our vendors, acting on our behalf, may deliver an advertisement to you for that property or based on that search term. We also engage vendors to deliver online advertisements to consumers whose online behaviors on sites other than our own sites indicate that they may be interested in travel, or to help us deliver advertisements to consumers based on their publicly available social networking information. For example, if we know that you have stayed with us before, we may, through our vendors, deliver an online advertisement to you or your social networking friends. Some of our vendors may use anonymous data, such as demographic data, received from third parties to assist in the delivery of our advertisements to you.

Sensitive Information
The term "sensitive information" refers to information related to your racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership. We do not generally collect sensitive information unless it is volunteered by you. We may use health data provided by you exclusively to serve you better and meet your particular needs.

Personal Information From Children
Except where required by local laws, we do not knowingly collect personal information from individuals under 15 years of age. As a parent or legal guardian, please do not to allow your children to submit personal information without your permission.

Mobile and Location-Based Services
You can access our websites from a web-enabled mobile device to find a hotel (including clicking to call the hotel) or view or cancel a reservation. In addition, you can download an application to your Android phone or iPhone to provide additional functionality as described below. Using these applications you can find a hotel; book, view or change reservations; access your Loyalty Program account and book a reward stay. To book a reservation, you will be required to enter your name, address, email address and phone number, and you may be required to enter a credit card number. To view or change reservations, you will be required to sign in to your Loyalty Program account or enter your confirmation number and either your last name or last four digits of the credit card on the reservation. To sign in to or access your Loyalty Program account, or to book a reward stay, you will be required to enter your username or Loyalty Program number and your password or PIN. You can choose whether or not the application retains your Loyalty Progam login information, to make it easier to access your Loyalty Program account through the application in the future.

If you have downloaded the application to a device such as an Android phone or iPhone, you can use the device's Global Positioning System (GPS) technology to locate a hotel near you. No personally identifiable information is retained to deliver this location based service.

For certain properties, we also make available a "virtual concierge" application, which may be pre-loaded on a CCR owned device, or may be downloadable to your web-enabled mobile device. Using these applications, you can order services from the hotel, such as room service; access our websites; access third-party websites, including local attractions and social media; and book a reservation. To order services from the hotel, you will be required to enter your name and room number, and you can request order confirmation via SMS messaging. If you request SMS confirmation, you will be required to enter your phone number and carrier. If you book a reservation, you will be required to sign in to your Loyalty Program account or enter your confirmation number and either your last name or last four digits of the credit card on the reservation.

Links to Third-Party Websites
Our site and our mobile applications may contain links to third parties' websites. Please note that we are not responsible for the collection, use, maintenance, sharing, or disclosure of data and information by such third parties.

Other third-party websites include the landing page of the high-speed internet providers at our hotels, as well as social media sites (such as Facebook and Twitter) on which CCR or our properties may have accounts or fan pages where you may be able to post information and materials.

If you provide information on third-party sites, the privacy policy and terms of service on those sites are applicable. We encourage you to read the privacy policies of websites that you visit before submitting personal information.

Protecting Personal Information
CCR will take appropriate measures to: (i) protect personal information collected against unauthorized access, disclosure, alteration or destruction, and (ii) keep personal information accurate and up-to-date, consistent with applicable law. We also seek to require our affiliates and service providers with which we share personal information to exercise reasonable efforts to maintain the confidentiality of personal information about you. For online transactions, we use technology to protect the personal information that you transmit to us via our site. Unfortunately, however, no security system or system of transmitting data over the Internet can be guaranteed to be entirely secure.

For your own privacy protection, we encourage you not to include sensitive personal information in any emails you may send to us. Please do not send credit card numbers or any sensitive personal information to us via email.

We will not contact you by mobile / text messaging or email to ask for your confidential personal information or credit card details. We will only ask for your confidential personal information or credit card details by telephone when you are booking a reservation or promotional package by telephone. We will not contact you to ask for your Loyalty Program account log-in information. If you receive this type of request, you should not respond to it.

Changing and Accessing Your Personal Information
If you are an Loyalty Program member, the information you provided to us at the time of registration may be accessed, reviewed and updated at any time by signing in using your Username (or Loyalty Program number) and Password (or PIN), and clicking on "my profile."

To the extent required by applicable law, you may be able to request that we inform you about the personal information we maintain about you and, where appropriate, request that we update, correct and/or suppress personal information about you that we maintain in our active database. We will make all required updates and changes within the time specified by the applicable law and, where permitted by law, may charge an appropriate fee to cover the costs of responding to the request. Such requests must be submitted in writing to the following address: Crown & Champa Resorts Customer Privacy Department, Champa Building, 3rd Floor, Male', Maldives 20187. To protect your confidentiality, we can only respond to such requests to the email address that you have registered or otherwise provided to us. Please remember that if you make such a request, we may not be able to provide you with the same quality and variety of services to which you are accustomed.

In addition, in some circumstances based on applicable law, you may request that we cease sharing personal information about you with our business partners or that CCR cease the use of personal information about you on the grounds that such personal information was acquired by unjust means or used in violation of law by sending your written request to: Crown & Champa Resorts Customer Privacy Department, Champa Building, 3rd Floor, Male', Maldives 20187. We will seek to honor those requests consistently with applicable law.

Retaining Personal Information
We retain personal information about you for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by applicable law.

Choices - Marketing Communications
If you have given us your contact information (mail address, fax number, email address or phone number), we may want to inform you about our products and services or invite you to events by email, telephone, mobile / text messaging (including SMS and MMS) or post.

If you are an Loyalty Program member, you may receive additional communications from us, including Loyalty Program statements, third-party news and offers specifically for Loyalty Program members, and co-branded messages from our business partners. Loyalty Program members of certain levels in certain states may also receive post-stay emails from us. You may change the communications you receive from us by logging onto your account online and managing your subscriptions, or by contacting us in the manner described below.

If you prefer not to receive marketing materials from us, you may change your preferences at any time by: (i) sending us an email to ecommercemanager@crownandchamparesorts.com; (ii) writing to us (and include your email address) at Crown & Champa Resorts Customer Privacy Department, Champa Building, 3rd Floor, Male', Maldives 20187; or (iii) using the unsubscribe function in the email you receive from us. We will update your preferences as soon as reasonably practical.

Please note, however, that if you "opt-out" as described above, we will not be able to remove your personal information from the databases of affiliates, franchisees or business partners with which we have already shared your personal information (i.e., to which we have already provided your personal information as of the date of your opt-out request).

Policy Modifications
We may modify this Policy from time to time. When we make material changes to this policy we will post a link to the revised policy on the homepage of our site. You can tell when this Policy was last updated by looking at the link and at the date at the top of the Policy. Any changes to our Policy will become effective upon posting of the revised Policy on the site. Use of the site following such changes constitutes your acceptance of the revised Policy then in effect.

Contact Us
If you have any questions about this Policy or how CCR processes your personal information, please contact us by email to: ecommercemanager@crownandchamparesorts.com or by postal mail to: Crown & Champa Resorts Customer Privacy Department, Champa Building, 3rd Floor, Male', Maldives 20187.

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