PRIVACY POLICY

This privacy policy (this "Policy") is presented by TRH Operating Company LLC d/b/a Topping Rose House (“TRH” or “we” or “us” or “our”) and applies in respect of any and all information we collect when you visit this web site, www.toppingrosehouse.com (the “Site”).  This Policy explains our practices regarding information obtained from sources other than the Site, such as written or verbal communications or information collected when you visit our Property.  Words and phrases defined in the Terms and Conditions for Use of the Site shall have the same meaning in this Policy.

BY ACCESSING USING, VIEWING, TRANSMITTING, CACHING OR STORING THIS SITE OR ANY OF ITS SERVICES, FUNCTIONS OR CONTENTS, YOU SHALL BE DEEMED TO HAVE AGREED TO EACH AND ALL THE TERMS AND CONDITIONS SET FORTH IN THIS POLICY, WITHOUT MODIFICATION. IF YOU DO NOT AGREE, PLEASE CEASE USE OF THE SITE AND LEAVE THE SITE IMMEDIATELY.

1.   Personal Information We Collect

During TRH’s interaction with you, and in conducting our business, TRH may collect personal information which may include: your name and contact information, including physical address, email address and telephone number; information related to your reservation, stay or visit to the Property; purchase of products or services; personal characteristics, including date of birth, gender and nationality; passport number and date and place of issue; payment information; guest preferences; marketing preferences; method of payment; credit card details, including the three or four digit CVV code; amount of charges for stays at the Property; reviews and opinions about our Property; information needed to provide products or services; and other types of information that you choose to provide to us.

2.    Use of Personal Information Collected About You

We use your personal information to provide the products and services you request from TRH, or which are part of a purchase you have made. In addition, we may use the information to: improve TRH's services; ensure the Site, products and services are of interest to you; and to process bookings and reservations. We also use the information to provide or offer you newsletters, promotions and featured specials as well as to market to you the services of TRH and its affiliates.

3.    Cookies and Use of Non-Personal Information

a.    When you visit and interact with the Site, TRH and third parties with whom TRH has contracted to provide services to TRH, may collect non-personal information (for example, a catalog of the Site pages you visit).

b.    The 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 are small text files which a website may put on your computer or mobile device when you first visit a site or page.  The cookie will help the website, or another website, to recognize your device the next time you visit.  There are other ways to do the same thing.  We use the term “cookies” in this policy to refer to all files that collect information in this way.  If you want to remove or block cookies at any time from your computer, you can update your browser settings.  There are many functions that cookies serve.  For example, they can help us to remember your username and preferences, analyze how well the Site is performing, or even allow us to recommend content we believe will be most relevant to you.  Certain cookies contain personal information – for example, if you click to “remember me” when logging in to make a booking, a cookie will store your username.  Most cookies won’t collect information that identifies you, and will instead collect more general information such as how users arrive at and use the Site, or a user’s general location.  Generally, our cookies perform up to three different functions:

i.    Essential Cookies - Some cookies are essential for the operation of our website. These cookies enable services for which you have specifically asked.

ii.    Performance Cookies - These cookies collect anonymous information on the pages visited. For example, we might use performance cookies to keep track of which pages are most popular, which method of linking between pages is most effective, and to determine why some pages are receiving error messages

iii.    Functionality Cookies - These cookies remember choices you make to improve your experience.  For example, cookies may be used to enable you to save a room into a wish list.

We also use or allow third parties to serve cookies that fall into the three categories above.  For example, like many companies, we use Google Analytics to help us monitor our website traffic.  We may also use third party cookies to help us with social media, market research, revenue tracking, improving site functionality and monitoring compliance with our terms and conditions and copyright policy.

c.    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 the 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.

d.    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.

 

4.    Sensitive Information

The term "sensitive information" refers to information you may consider to be sensitive which, for the purposes of this Policy means details related to your racial or ethnic origin, political opinions, sexual preferences, religion or other beliefs, health, criminal background or trade union membership. We do not collect sensitive information unless it is volunteered by you.

5.    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.

6.    Links to Third-Party Websites

The Site may contain links to third parties' websites, including to third party service providers that assist us in managing restaurant reservations and hotel bookings. Please note that we are not responsible for the collection, use, maintenance, sharing, or disclosure of data and information by such third parties. 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.

7.    Protecting Personal Information

a.    TRH will take measures that it deems appropriate 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 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 the Site.

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

8.    Changing and Accessing Your Personal Information

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 privacy@toppingrosehouse.com.

9.    Retaining Personal Information

We retain personal information about you for the period necessary to fulfill the purposes outlined in this Policy (or a shorter period, in our sole discretion) unless a longer retention period is required or permitted by applicable law.

10.    Marketing Communications

a.    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.

b.    If you prefer not to receive marketing materials from us, you may elect to unsubscribe using the unsubscribe function in the emails 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 third party service providers with which we have already shared your personal information.

11.    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 Site. 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.

12.    Contact Us

If you have any questions about this Policy or how TRH processes your personal information, please contact us by email to privacy@toppingrosehouse.com.