Effective: January 1, 2020
Collection of Personal Information
Use of Personal Information
Sharing of Personal Information
Social Sharing Features
Analytics Services Provided by Others
Transfer of Personal Information to the U.S. and Other Countries
Your California Privacy Rights
Additional Disclosures for Individuals in Europe
COLLECTION OF PERSONAL INFORMATION
The types of personal information we collect about you depend on your interactions with us and are described in more detail below.
Personal Information You Provide Directly
We collect personal information directly from you when you engage in any of the activities listed below:
- Create an online account for our Services;
- Participate in any interactive features of our Services like make a reservation at Miyako Hotel Los Angeles, Miyako Hybrid Hotel, or restaurants operated by these hotels (collectively, “Hotels”);
- Call, email, fax, or visit KEA by, for example, contacting the Hotels to inquire about our Services, make a reservation, or request customer support;
- Make a payment at the Hotels;
- Subscribe to receive our emails or newsletter, or participate in a promotional offer;
- Participate in a promotional offer; and
- Otherwise communicate with us.
The types of personal information we collect directly from you may include your name, contact information (such as email address, postal address, phone number, and fax number), credit card and other payment information, guest preferences (such as room preferences, accommodations and amenities you request or we became aware of during your prior visit or stay), information about previous stays at the Hotels, information about your employer (for example, if you are traveling for business), government-issued identification, important dates and times (such as an anniversary or special occasions), language preferences, date of birth, affiliation with organizations whose members are offered special rates, gender, travel itinerary, and any other information you choose to provide.
Personal Information We Collect Automatically
We automatically collect personal information when you access or use our Services, visit us, stay as a guest in our Hotels, or otherwise interact or transact business with us. The types of personal information we collect automatically may include:
- Transactional Information: We collect information about your purchases and transactions with us, including records of your reservations to stay at the Hotels or host or attend an event at the Hotels, such as information about your reservations, price or rate, and date and location of the transaction.
- Log Information: We collect information related to your access to and use of the Services, including the type of browser you use, access times, pages viewed, your IP address, and the page you visited before navigating to our Services.
- Information Collected for Security Purposes: Video recordings and images are collected by security systems including video cameras and CCTV we install in our premises, facilities or offices for security, fraud, and loss prevention purposes.
Personal Information We Collect from Other Sources
We may also collect personal information about you from other sources. For example, we may collect your name, guest preferences, reservation dates, payment information, age,) from travel agencies and providers of online booking platforms that allow you to make reservations at the Hotels. If you stay at our hotels for a corporate stay, we may also collect your name, guest preferences, information about your employer, age, and gender from individuals who make reservations on your behalf such as representatives of your employer who make reservations for corporate stays.
Personal Information We Derive
We may derive information or draw inferences from you based on the information we or our partners collect. For example, we may make inferences about your location based on your IP address.
USE OF PERSONAL INFORMATION
We use the personal information we collect for the following purposes:
- Provide you with the services you request or reasonably anticipated within the context of our ongoing business relationship, and perform our contractual obligations;
- Communicate with you about your online account, and send you information about our services, promotions, and events that you request or we think might be of interest to you see Your Choices below for information about how to opt out of these communications at any time);
- Maintain, administer, and improve the Services;
- Monitor and analyze trends, usage, and activities in connection with our services, perform business analyses, and for other internal purposes that are reasonably aligned with your expectation based on your relationship with us or compatible with the context in which you provided the information;
- Customize and personalize your use of the Services;
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, prosecute those responsible for that activity, and protect the rights of KEA and others;
- Comply with a legal obligation;
- To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
- Identify and repair errors that impair the intended functionality of our Services;
- Send you technical notices, updates, security alerts, and support and administrative messages and to respond to your comments, questions, and customer service requests;
- Personalize our services according to guest preferences;
- Debug to identify and repair errors that impair existing intended functionality;
- Conduct internal research and development activities; and
- Carry out any other purpose described to you at the time the information was collected.
SHARING OF PERSONAL INFORMATION
- With vendors, service providers, and consultants that perform services for us, including companies that provide website hosting services, data analytics services, and IT and security services;
- With business partners that provide services for Hotel guests and visitors including providers of online booking platforms and providers of transportation services;
- In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements;
- If we believe your actions are inconsistent with our user agreements or policies, if we believe you have violated the law, or to protect the rights, property, and safety of KEA or others;
- With our legal, financial, insurance and other advisors in connection with the kinds of corporate transactions described above or in connection with the management of all or part of KEA’s business or operations.
- In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company; and
- With your consent or at your direction.
We may also share aggregated or de-identified information that cannot reasonably be used by those third parties to identify you.
SOCIAL SHARING FEATURES
The Services may offer social sharing features and other integrated tools (such as the ability to share information on Facebook, Twitter and Pinterest), which let you share actions you take on our Services with other media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.
ANALYTICS SERVICES PROVIDED BY OTHERS
TRANSFER OF PERSONAL INFORMATION TO THE U.S. AND OTHER COUNTRIES
KEA is based in the United States and we process and store personal information in the U.S. and other countries where servers of our service providers are located. Therefore, we and our service providers may transfer your personal information to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction.
If you create an account with the Miyako Hybrid Hotel, you may update and correct certain account information you provide to us at any time by logging into your account or emailing us at Privacy@KEA-US.COM. If you wish to delete or deactivate your account, please email us at Privacy@KEA-US.COM or call us at 1-833-622-6220 but note that we may retain certain information as required by law or for legitimate business purposes.
You may opt out of receiving promotional emails or text messages from us by following the instructions in those emails or text messages or by following opt-out instructions included in those messages. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.
YOUR CALIFORNIA PRIVACY RIGHTS
Consumers residing in California are afforded certain additional rights with respect to their personal information under the California Consumer Privacy Act (“CCPA”)(California Civil Code Section 1798.100 et seq.) and the “Shine the Light” Law (California Civil Code Section 1798.83). If you are a California resident, this section applies to you.
California Consumer Privacy Act
Additional Disclosures Related to the Collection, Use, Disclosure of Personal Information
Collection and Use of Personal Information: In the preceding 12 months, we have collected the following categories of personal information: identifiers, financial information, characteristics of protected classifications under California or U.S. law, commercial information, internet or other electronic network activity information, audio or visual information, professional or employment-related information, and inferences drawn from any of this information to create a profile reflecting the consumer’s preferences. For examples of the precise data points we collect and the sources of such collection, please see “Collection of Personal Information” above. We collect personal information directly from you (for example, when you make a reservation to stay at the Hotels), automatically when you access or use our Services or visit the Hotels, and from third-party sources as described in the “Personal Information We Collect from Other Sources” section above. We collect personal information for the business and commercial purposes described in “Use of Personal Information” above.
Disclosure of Personal Information:
Disclosure of Personal Information: We may share your personal information with third parties as described in the “Sharing of Personal Information” section above. In the preceding 12 months, we have disclosed the following categories of personal information for business or commercial purposes: identifiers, financial information, characteristics of protected classifications under California or U.S. law, commercial information, internet or other electronic network activity information, audio or visual information, professional or employment-related information, and inferences drawn from any of this information to create a profile reflecting the consumer’s preferences.
No Sale of Personal Information: We do not, and will not, sell your personal information, and we have not sold your personal information in the preceding 12 months.
Your Consumer Rights
If you are a California resident, you have the right to request (1) more information about the categories and specific pieces of personal information we have collected, sold, and disclosed for a business purpose in the last 12 months, (2) deletion of your personal information, and (3) to opt out of sales of your personal information, if applicable. You may make these requests by calling 1-833-622-6220, emailing us at Privacy@KEA-US.COM, submitting a request via our CCPA Consumer Request Form or submitting a request in person at the Hotels. We will verify your request by asking you to provide information related to your recent interactions with us, such as information regarding a recent visit to one or both of the Hotels. To designate an authorized agent to make these requests on your behalf, please contact us . You also have the right not to be discriminated against for exercising your rights under the CCPA.
Shine the Light
California law permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes. KEA does not disclose personal information about you to third parties for the third parties’ direct marketing purposes unless we have obtained your prior affirmative consent to such disclosure. For more information, please contact us.”
ADDITIONAL DISCLOSURES FOR INDIVIDUALS IN EUROPE
If you are located in the European Economic Area or Switzerland, you have certain rights and protections under the law regarding the processing of your personal data.
Legal Basis for Processing
When we process your personal information, we will only do so in the following situations:
- We need to use your personal information to perform our responsibilities under our contract with you (e.g., processing payments for and providing the services you have requested).
- We have a legitimate interest in processing your personal information. For example, we may process your personal information to provide you with the services you request, send you marketing communications, to communicate with you about changes to our services, and to provide, secure, and improve our services.
- We find such processing is necessary to comply with our legal obligations.
- We have your consent to do so. When consent is the legal basis for our processing, you may withdraw such consent at any time.
Data Subject Requests
You have the right to access personal information we hold about you and to ask that your personal information be corrected, erased, or transferred. You may also have the right to object to, or request that we restrict, certain processing activities. If you would like to exercise any of these rights, please contact us.
We store the personal information we collect on you for as long as is necessary for the purpose(s) for which we originally collected it, or for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.
Questions or Complaints
If you have a concern about our processing of personal information that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. For contact details of your Data Protection Authority, please see:
21381 S. Western Avenue
Torrance, California 90501