THE BREAKERS PALM BEACH, INC.
Last Updated: December 23, 2022
As described in more detail through our Privacy Policy and our Notice of Additional Privacy Rights for California Residents, The Breakers Palm Beach, Inc. and its affiliated companies, subsidiaries and properties (“The Breakers”) are committed to safeguarding and respecting the privacy of Personal Information that we maintain about our guests, members, retail customers, restaurant patrons and visitors on our websites (thebreakers.com, weddingsbythebreakers.com, johnwebstergolf.com, breakerswestclub.com, viaflagler.com and membershipsbythebreakers.com), (collectively, the “Services.”)
The term “Personal Information” shall have the meaning used in our Privacy Policy and Notice. In this CA Notice at Collection, we use the words “The Breakers,” “us,” “our,” or “we” to refer to The Breakers, and “you” and “your” to refer to our guests, retail customers, restaurant patrons and online visitors.
HOW AND WHAT PERSONAL INFORMATION WE COLLECT
Personal Information We May Collect When You Use Our Websites, Apply for Membership or Communicate with Us
When you or your agent contact us, make reservations, apply for membership, or access our websites and mobile application, we may collect the following types of Personal Information:
- Audio Information, such as:
- Audio recordings of your telephone conversation with our employees and call center staff for quality assurance and legal compliance
- Characteristics of Protected Classifications, such as:
- Gender, age, disability accommodations, or national origin
- Commercial Information, such as:
- Dates of stay or other Services, accommodation requirements or preferences, reason for your stay or visit, names of those who may be staying or using the Services, promotional specials selected
- Customer Records Information, such as:
- Travel history, purchase history with us, or medical information provided for allergy or disability accommodations
- Geolocation Data, such as:
- Physical location of your device via your IP address
- Identifiers, such as:
- Name, address, date of birth, e-mail address, phone number, unique cookie identifier or similar identifier, membership number, or Internet Protocol (“IP”) address
- Inferences, such as:
- Your interests and hobbies drawn from the other categories of Personal Information
- Internet Activity or Other Similar Network Activity, such as:
- Type of internet connection, the equipment used to access our website(s), mobile application or mobile application, usage information, browsing history, search history or information relating to your interaction with our website(s) through the use of “cookies,” beacons, pixel tags, mobile ad identifiers, or similar technologies
- Professional or Employment-Related Information, such as:
- Job title, profession, income and employer information (e.g., company name, company address) provided for a membership application, in connection with your reservations, use of our Services or an event
- Sensitive Information, such as:
- Payment information used for reservations, membership, or other purchases made through the Services, and driver’s license or other government identification used for identity verification and security purposes; other Sensitive Information such as personal, professional or business affiliations, race/ethnicity, sexual orientation, or religious beliefs are not actively collected through the Services, but you may be able to voluntarily provide such Sensitive Information in any content or communications that you upload or make available to The Breakers while using our Services
Personal Information We May Collect When You Visit The Breakers
When you stay with us, dine in our restaurants, or shop at our resort, we may collect the following types of Personal Information:
- Characteristics of Protected Classifications, such as:
- Gender, age, disability accommodations, or national origin
- Commercial Information, such as:
- Dates of stay or visit, hobbies, interests, records and reasons for your stays or visits with us, products and services you purchased or considered, accommodation requirements or preferences, service issues, promotions used, activities or services used while staying with or visiting us, events attended, names of those who may be staying or using the Services
- Customer Records Information, such as:
- Travel history, purchase history with us, or medical information used for allergy or disability accommodations, incident reports with respect to any injuries, crimes our other disturbances that occur on The Breakers property, customer complaints contained in our log book, information regarding your activity on property
- Identifiers, such as:
- Name, address, phone number, date of birth, membership number, or email address
- Inferences, such as:
- Your hobbies and interests drawn from the other categories of Personal Information collected
- Internet Activity or Other Similar Network Activity, such as:
- The devices or equipment used to access our Guest WiFi or other networks at a The Breakers location, usage information, browsing history, search history or information relating to your interaction while using our network through the use of “cookies,” beacons, pixel tags, mobile ad identifiers, or similar technologies
- Photographic and Video Information, such as:
- Digital photographs you provide as identification during mobile check-in and video recordings from security cameras located throughout the premises
- Professional or Employment-Related Information, such as:
- Job title, profession, income and employer information (e.g., company name, company address) provided for a membership application, in connection with your reservations, use of our Services or an event
- Sensitive Information, such as:
- Payment information used for reservations, membership, or other purchases made through the Services, and driver’s license or other government identification used for identity verification and security purposes; other Sensitive Information such as personal, professional or business affiliations, race/ethnicity, sexual orientation, or religious beliefs are not actively collected through the Services, but you may be able to voluntarily provide such Sensitive Information to us in any content or communications that you upload or make available to The Breakers while using our Services
You hereby acknowledge and agree that any Sensitive Information you voluntarily provide to The Breakers may be processed as necessary to provide the Services in accordance with your instructions.
Personal Information Collected by Business Partners and Service Providers
Business Partners/Your Agents. We receive Personal Information from business partners, such as your travel agents, luxury tourism associations, and business or personal event planners so that we can process their customers’ registrations, provide Services, and be apprised of their customers’ accommodation needs and other preferences related to our Services.
We are not responsible for how these third parties collect, use, store, or otherwise process your Personal Information. You should review their privacy policies and practices before disclosing your Personal Information to them. If you have any questions about how they use your information, you should review their policies and contact them directly. Once we receive your Personal Information, we will process it in accordance with this Privacy Policy.
Cookies on our Websites. When you visit our websites, information is passively collected about you and your online activities through the use of cookies and other automated tracking technologies by data analytics companies including Google Analytics and Meta. The Personal Information that is collected through these automated technologies can be found under the subsection titled “Personal Information We May Collect When You Use Our Websites or Communicate with Us.”
These analytics service providers deliver statistical reports to us about how you and other people use our websites and demographics about our website visitors in an aggregate format. This aggregated data is stored in a format that generally cannot be used to identify you, but to the extent any of this aggregated data reasonably could be combined with other data so that it can be associated with you, we will treat it as Personal Information. Our analytics service providers have represented to us that they use the data collected on our websites for a limited number of lawful purposes, such as improving their product and providing analytics or advertising for us. Google may transfer this information to third parties, if required by law or if third parties process the information on behalf of Google. An overview of Google’s data privacy practices for Google Analytics may be available here. For more information on Google’s privacy practices generally, please review Google’s privacy policy here. To opt-out of being tracked by Google Analytics, you may be able to download and install the Google Analytics Opt-out Browser Add-on here. These Google services also may cause you to receive personalized ads based on your browsing behavior. You may be able to opt-out of receiving these personalized ads by using the settings here. See the section titled “How to Restrict Information Collected on our Website” for information about choices you may have regarding this cookie-related activity.
Other Service Providers. We also receive information from other vendors. Specifically, we use guest engagement facilitators such as INTELITY to assist with mobile check-ins, call center management and customer service providers such as NAVIS to manage and operate our call center, and digital advertising vendors such as Cendyn to provide marketing services.
The Personal Information that we receive from INTELITY can be found under the subsection titled “Personal Information We May Collect When You Visit The Breakers.” For more information on how INTELITY handles any Personal Information it collects from you, please review their privacy policy here.
The Personal Information that we receive from NAVIS can be found under the subsection titled “Personal Information We May Collect When You Use Our Websites, Apply for Membership or Communicate with Us.” For more information with respect to how NAVIS may collect and handle Personal Information, please see the NAVIS privacy policy here, and the NAVIS cookie policy here.
We may also collect the following types of Personal Information from Cendyn in order to provide you with opportunities and information suited to your interests (for more information regarding how Cendyn handles any Personal Information it collects from you, please refer to Cendyn’s privacy policy here):
- Characteristics of Protected Classifications, such as:
- Gender, age, or national origin
- Commercial Information, such as:
- Hobbies, interests, and products and services you purchased or considered
- Customer Records Information, such as:
- Travel history or purchase history
- Identifiers, such as:
- Name, address, date of birth, e-mail address, or phone number
- Inferences, such as:
- Your interests and hobbies drawn from the other categories of Personal Information we collect
- Professional or Employment-Related Information, such as:
- Education level, job title, profession, income and employer information (e.g., company name, company address)
WHY WE USE PERSONAL INFORMATION
We only use or disclose your Personal Information, including your Sensitive Personal Information, as described in this Privacy Policy and as permitted or required by applicable law.
Services and Identification. We use Audio Information, Characteristics of Protected Classifications, Commercial Information, Customer Records Information, Identifiers, Photographic Information and Sensitive Information to:
- Perform our contractual obligations to you, including providing you with any requested Services, necessary notices, confirmations or communications regarding your stay, event, or other use of our Services
- Verify the information that you provide to us
- Respond to requests that you make
- Charge and bill for services or products
- Protect the physical security and safety of the premises
Enhancing Your Visit. We use Commercial Information, Customer Records Information, Identifiers and Inferences to anticipate and fulfill your preferences and requirements, and to provide the accommodations and services for which we are known.
Long-term Relationship. To help build a long-term relationship, we may use Characteristics of Protected Classifications, Commercial Information, Customer Records Information, Geolocation Data, Identifiers, Inferences, Internet Activity and Professional or Employment-Related Information to:
- Provide you with promotional materials suited to your interests; and
- Send you emails, digital newsletters, personalized offers or other communications about our products and services.
Optimizing Website and Mobile Interaction. We use Commercial Information, Customer Records Information, Geolocation Data, Identifiers, and Internet Activity to:
- Analyze usage of our websites, the number of visits from different locations, and your online browsing activities so that we better understand the interests and demographics of the visitors to our websites and improve performance and effectiveness
- Customize the content you see on our websites and deliver our advertisements to you when you visit other websites
- Monitor and control the use of our websites in order to protect the security and integrity of our Websites and Services
- De-identify and aggregate Personal Information about usage of our websites that we use or share for statistical or analytical purposes (note that de-identified data is not subject to this Privacy Policy)
Membership Applications. For club membership applicants, we use Characteristics of Protected Classifications, Commercial Information, Customer Records Information, Identifiers, Professional or Employment-Related Information and Sensitive Information to verify eligibility and security requirements related to membership.
RIGHT TO OPT-OUT OF THE “SALE” OF PERSONAL INFORMATION
The Breakers does not engage in any direct sale of your Personal Information as a way to generate revenue, but we use certain third-party vendors which may have access to some of your data to help provide Services on our behalf as described in our Privacy Policy. The Breakers’ use of these third-party providers may cause you to receive targeted advertising based on your browsing behavior on our Services and elsewhere online. This third-party use of data may be viewed as a “sale” of Personal Information under California law, to the extent any data used for targeted advertising purposes reasonably can be linked to you, your device or your household.
As a California resident, you may have the right to opt-out of any such “sale” of Personal Information through targeted advertising by using our interactive request form, available at thebreakers.com/datarequest or through the “Do Not Sell My Personal Information” links available through our Services.