PRIVACY POLICY &
WEBSITE USAGE AGREEMENT

Halekulani Corporation dba Halepuna Waikiki views the management of personal data belonging to its customers to be a valuable privilege and is dedicated to ensuring that this information is protected, in full respect of the principles and correctness, lawfulness and transparency.

The term “Data” refers to any personal information that may be used to identify you as an individual. It may include, among other things, your name, contact number, email address, postal address, age, gender, passport, driver’s license details or identification document details.

Data we collect

Halepuna Waikiki collects Data about you to operate effectively and provide you with the best memorable experiences. We collect Data about you from a variety of sources, including through our website, reservations and call centers, social media and brand channels (e.g. Facebook, Twitter), or when you otherwise voluntarily provide it to us. In addition to the information that we collect from you directly, we also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly available sources.

The following Data may be collected from you:

  • Reservation information (such as name, email address, mailing address, phone number, fax number, and other personal information necessary to fulfill your reservation);
  • Payment information (including payment card numbers, billing address, bank account information, and in limited cases, we may collect credit status);
  • Guest Stay Information (including dates of arrival and departure, goods and services purchased; information necessary to fulfill special requests, such as health conditions that require specific accommodations);
  • Demographic data (such as age, gender, and location);
  • Copies of correspondence if you contact us. If you provide us feedback or contact us for support we will collect your name and e-mail address and possibly other personal information, as well as any other content that you send to us in order to reply.
  • Information related to your use and interaction with our website;
  • When you sign up on our mailing list, offers or events, or partner promotions (as part of co-branded promotion with another company)
  • If you participate in a survey. If the survey is provided by a third-party service provider, the third party’s privacy policy applies to the collection, use, and disclosure of your information;
  • Information collected through the use of closed circuit television systems, card key and other security systems; and
  • Employment data: There are also special circumstances if you are seeking employment. If you apply for a job posting, or become an employee, we collect personal information necessary to process your application. This may include, among other things, your Social Security Number and other personally information.

In your interactions with the website, you also have the following type of Data collected:

  • Email Links to Other Sites: If you receive email from us, we use certain tools to enable links to the websites of other companies or other companies’ social media sites that may contain a different privacy statement. We recommend that you read the privacy statement of each website that you visit.
  • Mobile Devices: We collect information from your mobile device such as unique identifying information broadcast from your device when visiting our website or when visiting one of our locations.
  • Third-Party Tracking: We participate in behavior-based advertising. This means that a third party may use technology (e.g., a cookie) to collect information about your use of our website so that they can provide advertising about products and services tailored to your interests. That advertising may appear either on our websites, or on other websites. You can opt-out of receiving advertising based upon your browsing behavior from some network advertising companies by going to the Network Advertising Initiative and the Digital Advertising Alliance websites, although to completely prevent advertising based upon your browsing behavior you should also disable the cookies on your browser. These third parties may also collect information directly from you as described in this Privacy Policy over time and across different websites.
  • Web Logs: We collect information from you, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet), domain name, click-activity, referring website, and/or a date/time stamp for your visit. In addition to information stored by our servers, we also use cookies and clear GIFs. Cookies may be removed by following instructions provided by your browser

In all cases, if you voluntarily share “Sensitive Information” (e.g. personal information related to your health) with us, that information will only be used as necessary to fulfill special requests (e.g. health conditions that require specific accommodations). For example, if you voluntarily convey a health-related need to us, we may store and use that information in order to provide a room with appropriate amenities. We do not collect or store sensitive information unless it is voluntarily provided by you.

Use of data collected

Halepuna Waikiki collects Data for the following purposes:

  • To fulfill Reservations and Other Purchases at our property (including hotel accommodations, food & beverage, Spa, Boutique, Concierge services, or other requested products or services);
  • To communicate with you.
  • To improve service to our customers and to track, process, and respond to customer care inquiries and to enhance and improve the customer’s experience.
  • To respond to your inquiries related to support, employment opportunities, or other requests.
  • To send marketing and promotional materials, including information relating to products, services, sales, or promotions.
  • For internal administrative purposes, as well as to manage our relationship with you.
  • For additional uses of Personal Information as described when you provide such information to us or for other purposes with your consent.

Sharing of Personal Data

In addition to the specific situations discussed elsewhere in this policy, we disclose Data in the following situations:

  • Service Providers. We share your personal information with service providers. Among other things service providers help us to administer our website, conduct surveys, provide technical support, and assist in the fulfillment of orders.
  • Public. Some of our websites provide the opportunity to post comments, or reviews, in a public forum. If you decide to submit information on these pages, that information may be publicly available.
  • Partner Promotion. We may offer contests, sweepstakes, or other promotions with third party partners. If you decide to enter a contest, sweepstakes, or promotion that is sponsored by a third party partner the information that you provide will be shared with us and with them. Their use of your information is not governed by this privacy policy.
  • Affiliates and Acquisitions. We share your personal information with our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control). We may also share your information if another company acquires our company, business, or our assets.
  • Other Disclosures with Your Consent. We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy.
  • Other Disclosures without Your Consent. We may disclose personal information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your personal information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for the shipment of products to or the provision of services by a third-party intermediary.

Access or Revision to Personal Data

We understand that you may like to know what personal information we hold about you. We are happy to assist with your request. We encourage you to protect your Data. You can make the following choices regarding your information:

  • Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in e-mails that you receive. Although we will remove your name from our mailing list after receiving your request within the timeframe permitted by law, you may still receive mailings from us that had been initiated prior to your name being removed. If you decide not to receive promotional emails, we may still send you transactional communications, such as those about your account, to fulfill orders you have made, to ask you to rate the product you purchased, or other service-related communications.
  • Promotional Mailings. If at any time you do not want to receive offers from us you can remove yourself from our mailing lists by emailing us (our contact information is below) with "NO SNAIL MAIL" in the subject line along with your name, address and zip code. Please note that our mailings are prepared in advance of them being sent. Although we will remove your name from our mailing list after receiving your request, you may still receive mailings from us that had been initiated prior to your name being removed.
  • Changes To Your Personal Information. We rely on you to update and correct your personal information. Most of our websites allow you to modify your account profile. Note that we may keep historical information in our backup files as permitted by law but no longer than necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law, or an individual request that we delete information about them.
  • Deletion Of Your Personal Data. Typically, we retain your personal information for the period necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law, or an individual request that we delete information about them. If required by law, upon request, we will grant a request to delete your personal information. When we delete personal information, it will be removed from our active database, but it may remain in archives where it is not practical or possible to delete it. In addition, we may keep your personal information as needed to comply with our legal obligations, resolve disputes, and/or enforce any of our agreements. Contact us if you would like more information about our retention period for a specific type of data.
  • Ability to object to processing. You may object to our continued processing of your data. If we receive an objection we will evaluate whether we are required by law to discontinue such processing.
  • Access To Your Personal Data. If required by law, upon request, we will grant reasonable access to the personal information that we hold about a user.
  • Online Tracking. We do not currently recognize automated browser signals regarding tracking mechanisms, including the "Do Not Track" header.
  • California Residents. California residents may be entitled to ask us for a notice describing what categories of personal information (if any) we share with third parties or affiliates for those parties to use for direct marketing. If you are a California resident and would like a copy of such notice, please submit a written request to us using the information in the “Contact Information” section below.

How We Protect Personal Data

We treat all Data that you provide to us as confidential information. While we use reasonable administrative, organizational and technical safeguards to protect your Data, no method of transmission over the Internet, or method of electronic storage is fully secure. In the event that we are required by law to inform you of any unauthorized access to your Data we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

Transmission Of Data To Other Countries

Your Data may be processed in the United States, where privacy laws may be less stringent than the laws in your country. By submitting your Data to us you agree to the transfer, storage and processing of your information in the United States. If you would like more information concerning our attempts to apply the privacy principles applicable in one jurisdiction to data when it goes to another jurisdiction, you can contact us using the contact information below.

Third Party Applications/Websites

We have no control over the privacy practices of websites or applications that we do not own.

Contact Information

If you have any questions, comments, or complaints concerning our privacy practices, or would like to ask for access, rectification, or deletion of your personal information, please contact us at the address below. We will attempt, where practical, to respond to your requests and to provide you with additional privacy-related information.

Email: myprivacy@halepuna.com

Mail: Halepuna Waikiki
Attn: General Manager – Privacy
2233 Helumoa Road
Honolulu, Hawaii, USA 96815

Fax: (+1)808.922.7012

If you are not satisfied with our response and are in the European Union you may have a right to lodge a complaint with your local supervisory authority.

Changes To This Privacy Policy

We may change our privacy policy and practices over time. To the extent that our policy changes in a material way, the policy that was in place at the time that you submitted personal information to us will generally govern that information. You will be provided with notice of material changes to the privacy policy.

Last Revised: April 1, 2019