1.0 Data Covered by This Privacy Statement

This Privacy Statement describes the privacy practices of The Inn at Orient for data that we collect:

1. through the website operated by us from which you are accessing this Privacy Statement, including www.theinnatorient.com.
2. through the software applications we use for reservations on either computers and or mobile devices; through social media pages and accounts that we control.
3. through email messages that we send you that link to this Privacy Statement and through your communications with us online or in person.
4. from third parties, and other sources, such as public databases, marketing partners and other third parties.
5. and when you visit or stay as a guest at our property or through other offline interactions.

2.0 The Data We Collect

2.1 What do we Collect

At touchpoints throughout your booking and stay, we collect Personal Data in accordance with the law, and to serve you better. Personal Data is information that may identify you as an individual or relate to you as an identifiable individual. We may collect and process the following types of Personal Data about you:

1. Name
2. Gender
3. Postal address
4. Telephone number
5. Email address
6. Financial information (such as credit and debit card number or other payment data)
7. Language preference
8. Date and place of birth
9. Nationality, passport, visa, or other government-issued identification data
10. Important dates: birthdays, anniversaries, and special occasions
11. Employer details (for business-related bookings)
12. Travel itinerary, tour group, or activity data
13. Prior guest stays or interactions, goods and services purchased, special service and amenity requests
14. Social media account ID, profile photo and other data publicly available, or data made available by linking your social media and loyalty accounts

In more limited circumstances, we may also collect:

1. Data about family members and companions, names, and ages of children

2.2 Preferences

We may also collect information about your Preferences that we use to make your current and future stays and experience with us more enjoyable, including information about your interests and other relevant information that we learn about you during your stay. This may also include any likes and dislikes about our services that you tell us about so that we can improve our services, and specific dietary, health restrictions or personal needs to ensure your wellbeing. We may also collect your “Personal Preferences,” that may include details of your special anniversaries (such as your birthday or wedding anniversary), what type of activities you prefer to take part in when staying with us, and your hobbies. Personal Preferences may also include details about who you usually travel with, their relationship to you, and your marital status.

2.3 Third Party Information

If you submit any Personal Data about other people to us or our Service Providers (e.g., if you make a reservation for another individual), you represent that you have the authority to do so and you permit us to use the data in accordance with this Privacy Statement.

3.0 Cookies and Other Data

3.1 Other Data

We may also collect “Other Data” that generally do not reveal your specific identity or do not directly relate to an identified individual. To the extent Other Data reveal your specific identity or relate to an individual, we will treat Other Data as Personal Data. Other Data includes information collected in a variety of methods:

3.2 From Your browser or device.

We collect certain data through your browser or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Apple), screen resolution, operating system name and version, device manufacturer and model, language, internet browser type and version and the name and version of The Site (such as the Apps) you are using. We use this data to ensure that The Site function properly.

3.3 From Cookies.

We collect certain data from cookies, which are pieces of data stored directly on the computer or mobile device that you are using. Cookies allow us to collect browser type, time spent on The Site, pages visited, referring URL, language preferences, and other aggregated traffic data. We use functional cookies to obtain the data for security purposes, to facilitate navigation, to display content more effectively, to collect statistical data, to personalize your experience while using The Site, and to recognize your computer to assist your use of The Site. We also gather statistical cookie data about use of The Site to continually improve design and functionality, understand how they are used and assist us with resolving questions. Advertising cookies further allow us to select which advertisements or offers are most likely to appeal to you and display them while you are using The Site. We also use them to send marketing emails and to track responses to online advertisements and marketing emails. You can learn more about cookies at: http://www.allaboutcookies.org/manage-cookies/index.html

You can choose whether to accept cookies by managing your tracking preferences by changing the settings on your browser. If, however, you do not accept cookies, you may experience some inconvenience in your use of The Site. For example, we will not be able to recognize your computer, and you will need to log in every time you visit. You also will not receive advertising or other offers from us that are relevant to your interests and needs. At this time, we do not respond to browser “Do-Not-Track” signals.

3.4 Third Party Advertising:

We may use third-party advertising companies to serve advertisements regarding goods and services that may interest you when you access and use The Site. To serve such advertisements, these companies place or recognize a unique cookie on your browser (including through use of pixel tags). If you would like more information about this practice, and to learn about your choices in connection with it, please visit http://www.networkadvertising.org/managing/opt_out.asp and http://www.aboutads.info/.

We collect data from pixel tags (also known as web beacons and clear GIFs), which are used with some areas of The Site to, among other things, track the actions of users of The Site (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of The Site.

3.5 Analytics

We collect data through Google Analytics which uses cookies and technologies to collect and analyze data about use of the Services. These services collect data regarding the use of other websites, apps, and online resources. You can learn about Google’s practices by going to https://policies.google.com/privacy in a new browser tab and opt out by downloading the Google Analytics opt out browser add-on, available at https://tools.google.com/dlpage/gaoptoutOpen in a new browser tab.

3.6 Your IP Address

We collect your IP address, a number that is automatically assigned to the device that you are using by your Internet Service Provider (ISP). An IP address is identified and logged automatically in our server log files when a user accesses The Site, along with the time of the visit and the pages that were visited. We use IP addresses to calculate usage levels, diagnose server problems and administer The Site. We also may derive your approximate location from your IP address.

3.7 Aggregated and Segmented Data.

We may aggregate data that we collect, and this aggregated data will not personally identify you or any other user. We may also use both Personal Data and Other Data to divide customers into segments, or groups, in order to provide more relevant advertising.

4.0 How and Where We Collect Your Data

4.1 When we Provide a Service

We collect Personal Data and Other Data for the purposes described in this Privacy Statement, such as providing and personalizing the Services, communicating with you, facilitating the loyalty programs and to accomplish our business purposes.

4.2 Site Interactions

We collect Personal or Other Data when you interact with our The Site, by performing such actions as, but not limited to, browsing, making a reservation, communicating with us, otherwise connecting with us or posting to social media pages, or signing up for a newsletter.

4.3 General Communications

We collect Personal Data when you make a reservation over the phone, communicate with us by email, by telephone or in person.

4.4 Internet Connected Devices

Internet-Connected Devices. We may collect Personal and Other Data from internet-connected devices available in our properties.

5.0 Why We Collect Your Data (Legal Basis)

5.1 Booking & Guest Registration

There are a number of activities associated with this purpose, such as: facilitating reservations and bookings of hotel accommodations and related services; engaging in pre‑arrival communications (logistics, changes, preferences, etc.); processing payments and security deposits. We collect data during these processes for the following reasons:

1. To complete the contract for the individual guest booking a room
2. To fulfill legitimate interests for the individual booking the room, for example, honoring his/her preferences, as well as for any individuals accompanying the primary guest (e.g., spouse, children, friends)
3. Fulfilling legal obligations of The Inn related to the financial transactions, such as the obligation to maintain books and records

5.2 On-Site Reception & Stay Services

There are a number of activities associated with this purpose, such as: facilitating check-in and check-out; processing payments; providing consistent and personalized service and advice about the on-site services (based on past usage or expressed preferences); providing concierge, luggage storage and parking services; making arrangements with third‑party providers on behalf of guests (such as coordinating tours and other sightseeing excursions; arranging taxi, shuttle and chauffeur services; and facilitating reservations and bookings at restaurants and events); administering and facilitating access to Wi-Fi; housekeeping services; and handling any other customer requests, inquiries and or complaints.

5.3 The Inn at Orient Operations & General Business

There are a number of activities associated with this purpose, such as: administering customer-care services to facilitate and address inquiries, comments and complaints about any of our services (such as in person, through phone lines, email, or on social media); handling security and fraud prevention; administering online services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and the hosting of data); and monitoring and analyzing usage of services and using data analytics to improve services, marketing, overall customer experience, and gathering feedback in order to improve existing services.

5.4 Emergency & Incident Response

There are a number of activities associated with this purpose, such as: ensuring the security of on-site services; responding to, handling and documenting on-site accidents and medical and other emergencies (including facilitating in‑house doctor services); actively monitoring properties to ensure adequate incident prevention, and response; requesting assistance from emergency services; and sending notifications and alerts in the event of incidents or emergencies (such as via SMS, email, call, audio-visual device prompts, etc.).

5.5 Legal & Compliance

There are a number of activities associated with this purpose, such as: complying with applicable laws; complying with legal processes; responding to requests from public and government authorities; meeting national security or law enforcement requirements; enforcing our terms and conditions; protecting our operations; protecting the rights, privacy, safety, or property of Konohassett LLC, guests, visitors and other relevant individuals; and allowing us to pursue available legal remedies and limiting the damages that The Inn may sustain.

5.6 Child-Related Services (for Parents & Legal Guardians)

There are a number of activities associated with this purpose, such as: Complying with the Terms and Conditions of your stay; facilitating reservations and bookings; preparing for and coordinating accommodations and services in accordance with guest preferences, instructions and expectations; and payment and billing services.

5.7 Marketing, Promotions, Contests & Third-Party Products

There are a number of activities associated with this purpose, such as: communicating about products and services that may be of interest to guests; providing personalized advertisements for products and services on selected websites; facilitating participation in sweepstakes, contests and other promotions (such as best vacation photo contests on social media); and handling customer requests, inquiries and complaints.

6.0 How and When We Share Your Data

6.1 Who we Share Data with

Our goal is to provide you with the highest level of hospitality and Services. We do not regularly share your data with other entities except as noted below:

1. Service Providers. We disclose Personal Data and Other Data to third-party service providers including, for example, companies that provide website hosting, data analysis, payment processing, order fulfilment, information technology and related infrastructure provision, customer service, email delivery, marketing, auditing, and other services.
2. When we are required to by Law or to meet our Terms and Conditions. We will use and disclose Personal Data as we believe to be necessary or appropriate:
   1. to comply with applicable law, including laws outside your country of residence.
   2. to comply with legal process.
   3. to respond to requests from public and government authorities, including authorities outside your country of residence and to meet national security or law enforcement requirements.
   4. to enforce our terms and conditions.
   5. to protect the rights, privacy, safety or property of Konohassett LLC, you or others.
   6. to allow us to pursue available remedies or limit the damages that we may sustain.

6.2 Limitations

We may use and disclose Personal Data to protect our operations, such as in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of The Inn business, assets or stock (including any bankruptcy or similar proceedings); except where we are not allowed to under applicable law.

7.0 Your Data, Your Choices: Your Privacy Preferences & Rights

At The Inn, we believe that you should have choices with respect to your data. We provide you with the options, information, and choices below to express your preferences: what and how much you share with us and when and how you hear from us.

7.1 Communications and Preferences

If you no longer wish to receive marketing-related emails, you may opt out by following the instructions in any such email you receive from us or directly contacting us and letting us know via email or phone.

7.2 Required Communication

Even if you choose to opt out of marketing-related emails, we may need to continue to send you transactional messages, such as information about your reservations or stays, including confirmation and pre-arrival emails, or account security updates.

7.3 Cookies and Other Data

For information on your choices related to Cookies and Other Data, please see the Section on Cookies and Other Data, above.

7.4 Request Related to Your Data

If you would like to request to access, change, delete, restrict the use of, or object to the processing of your Personal Data that you have previously provided to us (to the extent these rights are allowed by law), please let us know. For your protection, we may need to verify your identity before fulfilling certain requests. When permitted by law and appropriate, we may elect to charge a fee commensurate with the costs of responding to your request.

7.5 Respect for Guest Privacy

The Inn acknowledges and respects our guests’ privacy; and we will try to comply with your request as soon as reasonably practicable and consistent with applicable law.

8.0 Notice for California Residents

Customers who reside in California and have provided their Personal Data to us can request, once per calendar year, information about our sharing of certain categories of Personal Data to third parties. Such requests should be submitted to us at info@theinnatorient.com. California residents can find more information on exercising their rights under the CCPA by reading our California Consumer Privacy Statement or by calling 1-800-218-9316.

9.0 Notice for Nevada Residents

To exercise your individual rights under the Nevada Privacy Law (NRS Ch. 603A, Sec. 2(2)), please contact us at info@theinnatorient.com.

10.0 Withdrawal of Consent

If you have given us consent in relation to a particular action or activities, you can withdraw your consent at any time by contacting us.

11.0 Other Important Provisions

11.1 Entities other than The Inn

This Privacy Statement does not address, and we are not responsible for the privacy, data, or other practices of any entities outside of The Inn, including any third-party operating any site or service to which the Site links, payment service, and others. The inclusion of a link on the Site does not imply endorsement of the linked site or service by us. We generally have no control over, and are not responsible for, any third-party’s collection, use and or disclosure of your Personal Data.

11.2 Third Party Data Collection

In addition, we are not responsible for the data collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Data you disclose to other organizations through or the Apps or our social media pages.

11.3 Security

We seek to use reasonable organizational, technical, and administrative measures to protect Personal Data. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that security has been compromised), please notify us immediately via email or phone.

11.4 Retention

We will retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Statement unless a longer retention period is required or permitted by law. The criteria used to determine our retention periods include:

1. The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you keep using the Services)
2. Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period before we can delete them)
3. Whether retention is advisable considering our legal position (such as, for statutes of limitations, litigation, or regulatory investigations)

11.5 Sensitive Data

Unless specifically requested, we ask that you not send us, and you not disclose, on or through the Services or otherwise to us, any Sensitive Personal Data (e.g., social security number, taxpayer identification number, passport number, driver’s license number, or other government-issued identification number; credit or debit card details or financial account number, with or without any code or password that would permit access to the account, credit history; or information on race, religion, ethnicity, sex life or practices or sexual orientation, medical or health information, genetic or biometric information, biometric templates, political or philosophical beliefs, political party or trade union membership, background check information, judicial data such as criminal records, or information on other judicial or administrative proceedings).

11.6 Use of the Site by Minors

The Site is not directed to individuals under the age of sixteen (16), and we request that they not provide Personal Data through the Site.

11.7 Updates to This Privacy Statement

The “Last Updated” legend at the top of this page indicates when this Privacy Statement was last revised. Any changes will become effective when we post the revised Privacy Statement on The Site. If you would like to review the version of the Privacy Statement that was effective immediately prior to this revision, please contact us.

If you have any questions about this Privacy Statement, please contact us.

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