Last Updated: April, 2019
Diaoyutai MGM Hospitality, Ltd., including its subsidiaries and all of the hotels within the Diaoyutai MGM Properties (collectively "Diaoyutai MGM," "we" ) values your patronage and acknowledges that privacy is important to you. This global privacy statement (this “Statement”) describes the ways in which we collect, use and disclose your personal information during your visits to our hotels, including on-site registration, registration through the internet and our social media pages or from other sources. At Diaoyutai MGM, we endeavor to provide the best quality products and services to all our customers throughout the world. While this Statement sets out our general policies and practices which apply to all of our Diaoyutai MGM Properties throughout the world, there may be local variations depending on the local laws and regulations. Thus, our actual practices in various locations may be more restrictive than the general practices set forth herein. If you are a resident of the European Economic Area (EEA), this Statement is equally applicable to you.
Your usage of our products and/or services or your acceptance of this Statement shall mean that you understand and agree to the way in which we collect and process your personal information in accordance with this Statement. Diaoyutai MGM Hospitality, Ltd. reserves the right of final interpretation of this Statement.
- COLLECTION OF PERSONAL INFORMATION
We collect information from a variety of sources and in a variety of ways:
· When you visit Diaoyutai MGM Properties or Diaoyutai MGM web sites or our social pages or purchase any of our products or services, we may collect personal information from you. Such personal information may include but is not limited to: your name, gender, postal address, email address, phone number, and information related to your reservation or membership; information related to the purchase and receipt of our products or services; personal identity information, such as: nationality, passport number and date and place of issue; date of birth; travel history; payment related information, including: your credit or debit card number, financial information in limited situations, identification card number, passport number or other account or identification information; and any other types of information which you may provide at our request or otherwise.
· When and after you check in at our Diaoyutai MGM Properties, we collect additional information from you subject to local laws and regulations. We have installed closed circuit television and other devices to record your images in our public areas including our on-site services in our hotels in order to protect the safety and well-being of our guests, visitors and staff in accordance with local laws.
· If you apply for a job with Diaoyutai MGM or at a Diaoyutai MGM Property, we may ask for certain information about you including, for example, your work and education history, and your profile/résumé.
· When you visit Diaoyutai MGM Properties or Diaoyutai MGM web sites or our social pages, we may collect information about your purchases, reservations, and other consuming habits.
· When you use Wi-Fi services at Diaoyutai MGM Properties, we may collect information (directly or through third parties) about the web sites you visit, the type of device and browser you are using, your device identification number, your geographic location, bandwidth used, session time, or other similar information.
· When you visit Diaoyutai MGM web sites, we may collect information about the type of device and browser you are using, the unique number assigned to your server or Internet connection, your geographic location, and your interactions with Diaoyutai MGM web sites. We may use “cookies” and similar technologies that contain information that will be saved on your computer’s hard drive. Cookies enable us to gather data such as web pages visited, links clicked and material downloaded. Cookies also are used to put a unique identifier on your computer or other devices. This helps us to generate statistics regarding usage of Diaoyutai MGM web sites. There are different types of cookies including “browser” cookies (also known as html cookies) and Flash cookies (also known as Local Shared Objects). You can configure your browser to reject browser cookies or to notify you when browser cookies are offered so that you can accept or reject such cookies. However, if you reject browser cookies, you may not be able to conduct some transactions or use some services. Blocking or deleting browser cookies may not block or delete other types of cookies including Flash cookies.
· When you use integrated social media features on Diaoyutai MGM web sites, mobile applications, or other social media web sites, we may obtain information such as your name and e-mail address.
· We may obtain information about you from third parties, including entities that direct you to or are located at Diaoyutai MGM web sites or Diaoyutai MGM Properties, business partners, family members, and friends.
· We may collect information about you through online or offline surveys about customer preferences on a voluntary basis.
In addition, we collect other personal information in certain cases, such as:
· M life Rewards Participation: When you enroll in our M life Rewards program, you will receive an M life Rewards number and we will ask you to create a user ID and password. We also collect information to administer the M life Rewards program and profiles, including transaction and correspondence details, and to provide you with our M life Rewards websites (PC and Mobile) functionality (where available). The M life Rewards websites allow you to do such things as use your mobile device to manage your reservation, profile, preferences and concierge services. When you manage your profile online, you have the opportunity to provide additional information, such as your preferred airlines and your loyalty program account numbers with them, your room type preferences, your language preferences, your payment card account(s), and your email subscription preferences for receiving news, offers and information from us and our partners. Also, when you book a reservation, including a Rewards Reservation, or purchase M life Rewards Participation Points online, we may ask for additional specific account information such as corporate account number, group or convention code or travel agent number. If you apply for a payment card or other account with one of our partners via one of our advertisements or on our properties, you may have the option to automatically add this information as part of your M life Rewards Participation profile. The M life Rewards Participation is under preparation. You could register on our official web site by providing your name, gender, email address, birth date, mobile number, and postal address.
Based on the personal information which you provide, we may infer certain information based on the personal information. We will treat such inferred information with the same principles provided in this Statement as we treat the personal information we collect from you directly.
- AMENDMENT OF THIS STATEMENT
We may amend this Statement from time to time. When we make any amendments to this Statement, we will post a link to the revised Statement on the homepage of our site. In the event you have provided your contact information, such as email, we might inform you of such amendment by email. Any changes to our Statement will become effective upon posting of the revised Statement on our web site. If you use our products and services, it constitutes your acceptance of such revised Statement.
- MARKETING COMMUNICATIONS OPTIONS
According to the contact information which you have provided to us, we may inform you in accordance with any preferences you have expressed, and with your consent where required, about our products and services or invite you to events via email, online advertising, social media, WeChat, by postal mail, or by phone, etc.
If you are an M life Rewards member, you may change the communications you receive from us by logging on to your online account and managing your subscriptions, by writing to us (and including your email address) at Tower C2, Suites 807, Oriental Plaza, Dongcheng District, Beijing, P.R. China, 100738 Diaoyutai MGM, or by emailing us at email@example.com.
- RETENTION OF PERSONAL INFORMATION
We retain personal information about you long enough to fulfill the purposes outlined in this Statement, unless a longer retention period is required. We retain personal information collected in order to fulfill guest reservations for  years after the stay is completed. We retain other personal information for shorter periods of time if possible and if permitted by law. We will destroy your personal information as early as practicable and in a way that the information may not be restored or reconstructed.
If the information is printed on paper, it will be destroyed in a secure manner, such as by cross-shredding or incinerating the paper documents or otherwise. If the information is saved in electronic form, the personal information will be destroyed by technical means to ensure the information may not be restored or reconstructed at a later time.
- CHANGES OF AND ACCESS TO YOUR PERSONAL INFORMATION
Our customers will have the right to obtain from us the alteration of inaccurate personal data which they provide. Taking into account the purposes of the processing, our customers shall have the right to have incomplete personal data completed, including by making a supplementary statement.
Therefore, you will have the right to require us to alter, update, delete, or complete your personal information on our files, and give or withdraw your consent for us to process your personal information at any time. For instance, you may log in to your personal account on our web site where you can change your personal information. Alternatively, you may also send an email to us (see Contact Information) and request us to amend your personal data on your behalf or to instruct us to stop sharing your information with third parties.
- INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
In the provision of products and services to you in our hotels, we may need to share your personal information with other Diaoyutai MGM Properties which are located outside of your country of origin. We will ensure that all such transfers of your personal information are performed in accordance with applicable laws and regulations.
When we transfer your personal information to our subsidiaries and affiliates in countries, such other countries may have different data protection standards from the countries where you reside. In some situations, government agencies, security authorities or courts in such other countries may be entitled to have access to your personal information. By using our products and services, you understand and accept such different standards.
- PROTECTION OF PERSONAL INFORMATION
Diaoyutai MGM shall take into consideration the technology, cost of implement and the nature, scope, context and purposes of processing personal information, as well as the risks for the rights and interests of the persons posed by processing. Diaoyutai MGM shall implement appropriate technical and organizational measures, such as pseudonymization, which are designed to implement data-protection principles, such as data minimization, in an effective manner and to integrate the necessary safeguards into the processing in order to protect the rights of the customers.
Diaoyutai MGM shall implement appropriate technical and organizational measures to ensure that, by default, only personal data which are necessary for each specific purpose of the processing are processed. That obligation applies to the amount of personal data collected, the extent of their processing, the period of their storage and their accessibility. In particular, such measures shall ensure that by default personal data are not made accessible without the individual’s intervention to an indefinite number of natural persons.
In addition, it is our responsibility to implement appropriate technical and organizational measures to ensure a level of security proper to the risk, including:
(a) the pseudonymization and encryption of personal data;
(b) the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
(c) the ability to restore the availability and access to personal data in a timely manner in the event of a physical incident;
(d) a process for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing.
We have issued a code of conduct which protects the privacy of the personal information which we collect and protects the rights and interests of our customers according to laws and regulations. We have a team of information technology professionals who take effective and appropriate measures to ensure that the personal information we have is protected from unauthorized disclosure. The security team will manage and operate our security systems to protect your privacy and security when you use our products and services at our hotels. Our code of conduct imposes an obligation on all of our staff and employees to take necessary precautions to prevent misuse and improper disclosure of the personal information which you provide to us as you use our products or services.
We maintain a PCI compliance program. This compliance program generates audit reports concerning the adequacy and effectiveness of our IT related internal controls, including a PCI Attestation of Compliance signed by an external PCI Qualified Security Assessor. In the event of a security incident, we will notify regulators pursuant to applicable laws or regulations. We also request that our affiliates and service providers with whom we share personal information use reasonable care to maintain the confidentiality of personal information which they receive. For online transactions, we use all technological measures available to us to protect the personal information that we receive from you. Unfortunately, no security system or system of transmitting data over the Internet can be guaranteed to be entirely secure. Please do not send your payment card numbers or any other financial information to us by email.
- LINKS TO THIRD-PARTY WEBSITES AND SERVICES
Our web site may contain links to third parties' websites. Such third party web sites may have their own privacy policies. When you visit such third party web sites, please read their privacy policies prior to providing your personal information. We cannot guarantee that their privacy policies are consistent with ours.
In addition, we may also partner with certain Internet providers to offer Internet access to our guests. Their privacy policies are applicable when you access such web sites.
We may use third-party advertising companies to promote our advertisements for our products and services. To that end, such companies might place a unique cookie on your browser. If you prefer to opt out of such practice, you may download the AppChoices app at www.aboutads.info/appchoices.
- PERSONAL INFORMATION FROM CHILDREN
When children reach the age of 16, they are capable of giving consent to our collection and processing of their personal information. When children are below the age of 16, we may collect or process their personal data only when their guardians have given consent. We make reasonable efforts to verify that consent is given by the guardian pursuant to applicable laws and regulations.
We do not knowingly collect or allow the collection of personal information from persons under 18. If you are the parent or guardian of a person under 18 and believe that the person has provided us with personal information, you may contact us at firstname.lastname@example.org and request that it be removed from our active marketing database.
- PROCESSING OF PERSONAL INFORMATION RELATING TO CRIMINAL CONVICTIONS AND OFFENCES
We will carry out processing of personal data relating to criminal convictions and offences or related security measures only under the control of official authority or when the processing is authorized by Union or Member State law providing for appropriate safeguards for the rights and freedoms of our customers. Any comprehensive register of criminal convictions shall be kept under the control of official authority. As such, we will process personal data relating to criminal convictions only under the directions of official authority pursuant to local law.
The definition of “sensitive information” is “personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and genetic data, biometric data for the purpose of uniquely identifying of a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.”
In principle, we do not collect sensitive information unless you have given explicit consent to the processing of those personal data for one or more specific purposes; or processing is necessary to protect your vital interests or the vital interests of another person when you are physically or legally incapable of giving consent; or processing is necessary to protect public interest; or processing is necessary for us to comply with applicable laws and regulations.
When you visit and interact with Diaoyutai MGM websites and social pages, we collect other information that does not directly identify you about your use of the site, such as a catalog of the site pages you visit, and the number of visits to our sites (“Other Information”). We use Other Information, as well as data received from third parties, to deliver you email, online (on our sites and other sites) and mobile advertisements. We may also use Other Information to allow third-party partners to recognize you as one of their customers when you visit our websites or social pages so that they may provide more relevant offers to you.
- SHARING OF PERSONAL INFORMATION
We may share the personal information we collect from you with other members of the Diaoyutai MGM Properties, our suppliers and service providers and other third parties with which we conduct our business.
We may share your personal information with our business partners as they provide products and services at our hotels. For instance, we may work with rental car companies to provide you with rental car services at our hotels. In that case, we will share your personal information with such rental car companies in order to provide you with the service you require. We may share personal information with third-party providers of services such as concierge services, spa treatments, and dining services in our hotels. We may share your personal information with airlines, credit card or payment card companies, etc.
· Diaoyutai MGM Portfolio of Brands. We may share your personal information with our Diaoyutai MGM Portfolio of Brands, including: Diaoyutai, MGM Grand, Bellagio by MGM, and Mhub (钓鱼台，美高梅，宝丽嘉，和美高梅美荟).
· Service Providers: We may share your personal information with third parties in order for such third parties to provide products and services to you. Generally, our service providers are contractually obligated to protect your personal information and may not otherwise use or share your personal information, except as may be required by law. We may use service providers to provide news and promotional to you on our behalf in accordance with your preferences. Please see our Cookies Statement for more information.
· Other: In addition, we may disclose personal information in order to: (i) comply with applicable laws, (ii) respond to governmental inquiries or requests from public authorities, (iii) comply with valid legal process, (iv) protect the rights, privacy, safety or property of Diaoyutai MGM Properties, site visitors, guests, employees or the public, (v) permit us to pursue available remedies or limit the damages that we may sustain, (vi) enforce our websites' terms and conditions, and (vii) respond to an emergency.
- USE OF PERSONAL INFORMATION WE COLLECT
We may use information we collect about you for our own marketing purposes including notifying you of special promotions, offers and events via e-mail, direct mail, social media, telephone, text message, push notifications, and other means. We will ask for your consent for our use of your personal information where required by applicable laws.
When you want us to process your reservation at our hotels, we have an obligation to collect certain personal information from you, including your name, email address, mobile number, address, ID type and ID number, state/region, payment information, etc. Without such information, we may be unable to process your reservation at our hotels.
We may use the information we collect for non-marketing purposes including (1) validating your identity; (2) conducting statistical or demographic analysis; (3) processing, fulfilling, and tracking reservations, purchases, or other transactions; (4) complying with legal and regulatory requirements; (5) customizing your experience at Diaoyutai MGM Properties; (6) preventing fraud; and (7) cooperating with law enforcement or other government agencies for purposes of national security, public safety, or matters of public importance when we believe that disclosure of information is necessary or appropriate to protect the public interest (collectively “Non-Marketing Purposes”).
We may share the information we collect with our affiliates, business partners and other third parties.
How to Opt-Out
If you wish to opt-out of receiving marketing solicitations from us, or do not want us to share your personal information for marketing purposes with our business partners or other third parties, or with any individual Diaoyutai MGM Property, or Diaoyutai MGM subsidiary please e-mail us at email@example.com or write to us at:
Diaoyutai MGM Hospitality, Ltd.
Oriental Plaza, Tower C2, Suite 807
No.1 East Chang An Ave., Dongcheng District,
Beijing 100738, P.R. China
Although you may opt-out of the use and sharing of personal information for marketing purposes, we may still use and share information we collect for Non-Marketing Purposes.
Information collected by Diaoyutai MGM and any individual Diaoyutai MGM Property or Diaoyutai MGM web site is stored on secure servers, which are protected by firewalls and other industry standard security measures. These security measures are intended to protect these servers from unauthorized access. We will take all appropriate measures to strengthen our security systems, including fire walls for our servers, in order to protect security of your personal information when you use our products and services.
We are not in a position to enforce or control the security of the computers, electronic devices or other electronic communication methods that you may use to send e-mails and submit information to us over the Internet. You are responsible for ensuring that the computers, electronic devices and electronic communication methods you use will provide adequate security for communicating with us or with others. We are not responsible for the disclosure or interception of information that you send us due to security breach on your devices or over the Internet not within our control.
We are not responsible for the way of collecting personal information or privacy practices of other web sites, including web sites operated by our business partners or other third parties. You should review and understand the privacy policies posted on any linked sites you visit before using those sites or providing any personal information on such web sites.
· Loyalty program (M life Rewards) (on-going). If you are a member of the M life Rewards program, we may use your information to personalize your experience when you are using our products and services. We may use your personal information to provide to you news related to our services and products, marketing materials and personalize our advertisements and services through our web sites, by email as well as through our social pages.
· Service Management: We also use your personal information to manage programs in which you participate. We provide you with access to your account, inform you of your status of your qualifications for our awards, and facilitate communications between our properties in terms of providing services and products as well as collection related matters.
· Meeting and Event Planning: We may use your personal information to provide you with information about planning for meetings and events.
· Personalize our Services: We may use the personal information we collect from you to improve and customize our services to you, based on the preferences which you have expressed. We can, for example, provide offers custom-made to your personal preferences.
· Business purposes: We may use your personal information for data analysis, audits, security and monitoring and prevention of fraud, creating better products and services, improving our current products and services, and formulating strategies for new promotions, etc. You need to ensure that the information you provide is accurate and up to date.
· Emails, Text Message and Social Push Message: We may send you transactional or marketing messages through email, text messages and social push messages. As such, you should make sure that the email address, cellphone number and social media ID which you provide are current.
- COLLECTION OF PERSONAL INFORMATION FROM THIRD PARTIES
We may collect information related to you from third parties. The information will include airlines, credit card companies and other parties that are partners of Diaoyutai MGM Properties. In addition, we may also collect information from your social media apps, and from other third parties. The information will be used in a way consistent with the rules and policies contained in this Statement.
If you have any questions about this Statement or the way in which we process your personal information, or if you wish to either make a comment or a complaint, please contact us by email at firstname.lastname@example.org or by postal mail to Diaoyutai MGM at Tower C2, Suites 807, Oriental Plaza, Dongcheng District, Beijing, P.R. China, 100738. We will respond within 30 days or sooner if practicable.