Effective Date: November 1, 2021
Welcome to the website of Southbridge Napa Valley (“Southbridge,” “we,” “us,” or “our”).
We are based in California, and this policy incorporates protections for California residents provided under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”). Since we care about your privacy, we provide the same rights to all of our customers whether or not they are California residents. As discussed further below under Legal Disclaimers, your use of this Site and our services are subject to California and United States law. Although we are not subject to jurisdiction in the European Union, we further provide residents of the European Union with certain additional rights, as set forth below under the heading GDPR.
Summary of Your Rights
If you ever have any questions about how we use and store your personal information, you can submit those questions to us at firstname.lastname@example.org. Below is a non-exhaustive summary of the rights you have in this policy. This summary is only for your convenience: it does not change the details, exceptions and legal obligations that apply to these items set out in more detail below:
We do not and will not sell your data to any Third Parties for their marketing purposes. We share your personal information only with certain of our Service Providers to carry out our business with you.
You may request that we delete the personal information you provided to us at any time by sending your request to email@example.com or by phone at 707-967-9400, and we will delete it (unless there is a specific reason we need to keep it).
You may opt out of receiving marketing e-mails or the use of your personal data by us for direct marketing purposes. To opt out of the use of your personal data for this purpose, contact us at firstname.lastname@example.org or by phone at 707-967-9400. But you may miss out on seasonal offerings, event opportunities, and announcements.
We do not and have not sold or disclosed customers’ personal information for any purposes to anyone other than our Affiliates and Service Providers.
You cannot object to our sharing your information with our Service Providers, such as booking processors and credit card processors to facilitate your transactions, but be assured that our agreements with those providers prevent them from using your personal information for any other purposes.
You have a right not to receive any discriminatory treatment by the Hotel for the exercise of the privacy rights conferred by the CCPA, and we will not discriminate against you in any way for exercising those rights, which are described further below.
Notice of Collection
Who is Collecting Your Data
Categories of Information We Collect
We collect and store certain personal information about you at various points in order to provide you with products and services. As discussed further below, we are required to collect certain information from you, such as your name and residence in order to make a reservation with us. We also use this information and additional information we collect to customize our services to your preferences and provide you with products and services that we believe will appeal to you.
California defines certain categories of “personal information.” We collect information that falls into these categories directly from you and your electronic devices, as well as from other publicly available sources, as described more fully below in Why and How We Collect Your Information and it is disclosed in the following manner:
Category: (A) Identifiers
Examples of Types of Data: name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, etc.
Do We Collect it? YES
Category: (B) Additional Identifiers
Examples of Types of Data: telephone number, driver's license or state identification card number, education, employment, employment history, bank account number, credit card, number, debit card number, or any other financial information, medical information, or health insurance information
Do We Collect It? YES
Category: (C) Characteristics of protected classifications under California or federal law
Examples of Types of Data: age (if 40 and over), gender, marital status, race, national origin, and other protected classes
Do We Collect It? YES
Category: (D) Commercial information
Examples of Types of Data: records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
Do We Collect It? YES
Category: (E) Biometric information
Examples of Types of Data: genetic, physiological, biological or behavioral characteristics, that can be used to establish individual identity such as fingerprints or facial recognition
Do We Collect It? NO
Category: (F) Internet or other electronic network activity information
Examples of Types of Data: browsing history, search history, and information regarding a consumer's interaction with an Internet Web site, application, or advertisement
Do We Collect It? YES
Category: (G) Geolocation data
Examples of Types of Data: location of your electronic device
Do We Collect It? NO
Category: (H) Sensory data
Examples of Types of Data: audio, electronic, visual, thermal, olfactory, or similar information
Do We Collect It? NO
Category: (I) Professional or employment-related information
Examples of Types of Data: job history or performance evaluations
Do We Collect It? NO
Category: (J) Non-public education information
Examples of Types of Data: student education, financial or disciplinary records
Do We Collect It? NO
Category: (K) Inferences
Examples of Types of Data: drawn from any of the information above to create a profile about a consumer
Do We Collect It? YES
Why and How We Collect Your Information
We collect your information to manage our relationship with you and send you communications, and for a number of our other business purposes, including the following, which explain the business purposes referenced above:
You may be required to provide Personal Information to access some of our services and products, for example, to make reservations, check in to the hotel, sign up for our mailing list, request a brochure, or purchase gift certificates. We use this information to fulfill those requests and other transactions you undertake with us, including for internal analysis such as requesting feedback about your experience with Southbridge. This information will help us and you easily access your information after signing in, for future transactions, remember information so you will not have to re-enter it the next time you use our services and to provide more personalized and relevant services and information to you and others.
We use information for marketing purposes such as sending you promotional materials about Southbridge. If you would like to opt out of our use of your information for marketing purposes, or to be removed from our email list, you may contact us at email@example.com or by clicking the “unsubscribe” link in available at the footer of each marketing email communication.
When you provide information to use our services, you agree to receive communications from us by email, phone or other means (e.g., for account verification, changes and updates to the services, technical notices, and security notices). We may store and use the information you provide to us through such communications in the same ways we use transactional information. We are required to provide your information to certain of our service providers in order to store your preferences, process reservations, deploy email communications, as discussed below.
TECHNOLOGY AND ANALYTICS
We may use the information we have received to provide, test, improve, and monitor different areas regarding the effectiveness of our services, develop and test new features and products, monitor metrics, such as visitor count, traffic, and demographic trends, diagnose and solve technical problems. We may use third-party analytics tools that help us to measure usage trends and traffic for the site. These tools collect information sent by your computer or device or our site, including popular user habits, websites you visit, and other information that helps us improve our services. We collect and use such User analytics information in aggregate, in ways that do not identify individual Users.
“Do Not Sell My Personal Information”
Under California law, you have the right to opt out of the sale of your personal information. We do not sell personal information. While we may compile and provide aggregate statistics about our Users, and about sales, traffic patterns and related site information to Third Parties, these statistics will not include any personally identifiable information.
We may on occasion offer you financial offer or price of service difference in exchange for your agreement to allow us to obtain, retain or sell your personal information, such as if you register for an account or provide your email to our mailing list. The categories of information we are collecting that trigger the Financial Incentive are detailed above in the Categories of Information We Collect List This Financial Incentive is permitted under the California Consumer Privacy Act. Our Financial Incentive is based off a good-faith estimate for the value of your personal information, which we calculate by the benefit to us we attribute to the information, and which we believe is reasonably related to the financial incentive offered. If you wish to opt-in to the Financial Incentive you may do so by agreeing to register, subscribe, create an account, make purchases, providing us with your personal information, or otherwise interacting with this Site. If you wish to withdraw from the Financial Incentive you may do so at any time by sending an email to us at firstname.lastname@example.org.
Where Your Information is Stored
Any information collected through the site may be stored and processed in the United States or any other country in which Southbridge, its Affiliates or Service Providers maintain facilities.
Southbridge, its Affiliates, or Service Providers may distribute information that we collect about you across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located in the European Union or other regions with laws governing data collection and uses that may differ from United States law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction.
How Long We Keep Your Information
We will retain your information for as long as your account is active or as necessary to provide you services and to maintain a record of your transactions for financial reporting and compliance purposes. If you wish to cancel your account or delete your information, please contact us at email@example.com. Following deactivation or removal of your account, Southbridge, its Affiliates, or its Service Providers may retain information (including your Personal Information) and Public Content for a reasonable amount of time for backup, archival, and/or audit purposes. Information we have received about you may be accessed, processed and retained for an extended period when it is subject to a legal request or obligation, government investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm.
Your Rights to Access or Delete Your Data
If you so desire, we will provide you with a copy of your account data or delete your information at your request. Up to twice a year, you may ask us whether we are collecting, storing, using, disclosing or selling your personal information, what categories and/or specific pieces of personal information of yours we are collecting and storing, the categories of sources from which our personal information is collected, the business or commercial purpose for collecting your personal information, and whom we may have shared your information with, over the previous 12 months.
We will verify your identity for purposes of such a request to delete or a request to know. If you have an account on the Site, we will verify your request for information through your account. If you do not have an account, we will verify your request depending on the nature of the request. If you request to know the categories of information, we will request that you provide two pieces of information that match our records, which may vary depending on the information we have on file. If you request to know specific pieces of information, we will require additional verification to match three pieces of information on file, as well as a signed declaration. If you would like to designate an authorized agent to make such a request or your behalf you may do so by providing us with written and signed permission of such authorization, verify your identity with us as described above, and confirm that you provided the authorized agent permission to submit the request; or your agent must provide proof of a power of attorney.
You may request a copy of the personal information we have about you contacting us at firstname.lastname@example.org or by phone at 707-967-9400. If you request specific pieces of information, to verify your request you will need to provide a declaration to us via mail at 1020 Main Street, St. Helena, CA 94574 attesting to your identity. We will work diligently to respond to your requests and will provide you with a free response within 45 days.
If you would like us to delete your data, please contact us at email@example.com or by phone at 707-967-9400. Depending on the nature of the data that you request we delete, we may require you provide two or more data points that match the information in our file. Note that even if you request deletion, we may continue to retain and use information as may be authorized or necessary under California Law.
In order to ensure protection of your information from fraudulent requests, we require you provide us with additional information to verify your identity should you wish to access or delete your data. For your protection, in the event the requisite verification is not satisfied, we may deny the request for access to your account data or to delete your account.
Protecting Your Information
We make every effort to ensure that any data that we store about you is kept behind a secure firewall and is not accessible to the public in any way. Any sensitive information (such as credit card number) that we collect from you is encrypted/tokenized. We protect user data offline as well by restricting access to information to only those employees (for example, a Customer Care representative) who need the information to perform a specific job.
All employees are kept up to date on our security and privacy practices and are aware of the importance of keeping customer data secure and safe at all times. We also outsource certain of our data processing operations to third parties as discussed below, and we have agreements with those service providers that require them to maintain security over your information.
Although we use our best efforts to protect the security of your information and our system, and we have agreements in place with our processors requiring them to do the same, no transmission via the internet or storage of data can be guaranteed to be 100% secure. As a result of this and other factors beyond our control, we cannot guarantee the security of the information that you transmit to or through our Site. Therefore, you assume that risk by using the Site.
Southbridge makes every effort to ensure that the information provided by you on this Site or at the Hotel is only used to process your reservation, provide you with services, run our business, and to send you offers and other general communications about Southbridge. We may also use this information to send you correspondence regarding new features, services and special offers from us and/or our Affiliates that we think you’ll find valuable. This information is harvested from a secure area and encrypted for our customers’ protection. We will not sell or rent this information to others.
If you have any questions about the security of our Site, please feel free to contact us at firstname.lastname@example.org.
Any information that you voluntarily post on public-facing features (e.g., comments, reviews, etc.) of our site becomes available to other Users. You can manage your posts through the original platform it was published. If you remove information that you posted on the site, copies may remain viewable in cached and archived pages of the site, or if other Users or third parties have copied or saved that information.
We do not sell personal information, including that of minors under 16 years of age. The Site and Southbridge products and services are not directed at children under the age of 16. Southbridge does not allow anyone under the age of 16 to register for the Site or at the Hotel, and we do not knowingly collect or solicit any information from anyone under the age of 16. If you provide us with information about a minor under the age of 16, you are consenting to our use of that information on their behalf. If we learn that we have collected personal information from a child under age 16 without parental consent, we will delete that information as quickly as possible. If you believe that we have any information from or about your child under 16 to which you have not consented, please contact us via email at email@example.com or by phone at 707-967-9400.
A Cookie is a small text file which is stored in a dedicated area of your computer or device (tablet or smartphone) and accessed through your browser. It allows the sender to identify the computer or device wherein it is stored. Cookies from partner companies (third-party Cookies) can be placed on your computer via the pages of our website. Only the issuer of a Cookie is capable of reading or modifying the information contained therein.
The Cookies that we issue are used for the purposes described below, during the period of validity of the Cookie in question, subject to your choices resulting from the settings of your browser software when you visit our website, which you can change at any time.
- Adapt the presentation of our website, spaces and advertising content to your device’s display preferences (the language used, screen resolution, the operating system used, etc.), as appropriate, depending on the location data sent by your device with your prior permission, as well as your personal data;
- Store information about the forms completed on our website or about products, services or information chosen via our website; manage and secure access to restricted and personal spaces;
- Establish statistics and volumes related to our website traffic and the use of its various components (sections and content consulted) to enhance the value and usability of our services;
- To calculate the amounts payable to those involved in the advertisement circulation chain and compile statistics: identify and account for the total number of advertisements posted by us on our advertising spaces, including the number of views, number of clicks, and subsequent actions taken by these users to which these advertisements lead;
- Social networks: We may include third-party IT applications on our website which allow you to share content from our website with others or to inform them of your inquiry or opinion regarding our website content. This is true, in particular, of the ‘Share’ and ‘Like’ buttons from social networks such as Facebook, Twitter, etc. The social network providing these application buttons may identify you are using these buttons, even if you do not use them when you visit our website. Indeed, this type of application button can allow the social network in question to track your navigation on our website if your account on this social network is enabled on your computer or device at the time you visit our website. We have no control over the processes used by social networks to collect information about your navigation on our website and linked to the personal data at their disposal. We invite you to consult these social networks’ privacy policies to make yourself aware of the purpose of using the navigation information they may collect through these application buttons, including for advertising. In particular, these protection policies should enable you to exercise your choices on these social networks, particularly through setting your user account parameters on each of these networks.
- Advertising Space: Advertising content (graphics, animations, videos, etc.) disseminated through our advertising spaces may contain Cookies issued by third parties. These Cookies may, during the validity of the Cookies, allow for the number of visits to our website and the advertising content displayed on our advertising spaces to be counted, in particular for statistical and billing purposes.
- Targeted Advertising: Our websites may contain cookies issued by third parties (advertising agencies, audience measurement companies, targeted advertising providers, etc.) allowing them, during the period of validity of such cookies, to collect navigation information relating to the terminals connecting to our websites. We determine advertising content likely to correspond to the areas of interest identified in prior navigation via your computer or device.
Agreeing on Cookies: Registering a Cookie in a computer or device essentially depends upon the desires of the user, which can be expressed or modified at any time, free of charge, through the choices offered by the browser. If through your browser, you accepted the registration of Cookies in your computer or device, the Cookies integrated into the pages and content you view can be stored temporarily in a dedicated space on your device. They will be readable only by their issuer.
Refusing Cookies: If you refuse to accept Cookies in your device, or if you remove the Cookies registered, you will no longer be able to benefit from some features which are required to navigate some areas of our website. This will be the case if you try to access our content or services requiring a login. This will also be the case when we - or our service providers - are no longer able to recognize, for technical compatibility, the type of browser used by your computer or device, its language and display settings, or the country from which your computer or device appears to have connected to the Internet. In such cases, we disclaim any responsibility for the consequences of any degradation in the operation of our services due to our inability to record or consult the Cookies necessary for this operation which you have refused or deleted.
The configuration of each browser, for Cookie management and your choices, is different. This information is described in the help menu of your browser, which allows you to find out how to change your requirements regarding Cookies. Instructions to delete Cookies from all major browsers is described at this website: https://www.lifewire.com/how-to-delete-cookies-2617981.
Adobe Flash Player’s™ ‘Flash’ Cookies
Adobe Flash Player™ is a computer application that allows for the rapid development of dynamic content using the computer language ‘Flash.’ Flash (and similar applications) memorizes the settings, preferences, and use of this content through technology similar to cookies. However, Adobe Flash Player™ handles this information and your choices via a different interface from the one provided by your browser. The Flash Player Settings Manager can be accessed at this website: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html.
Do Not Track Signals
Some browsers have incorporated “do not track” features to enable users to make privacy and security choices. By using these settings, your browser may send a signal to our website not to collect tracking information. The Site does not track information from users through cookies if a “do not track” signal is received. Information tracked by the Site through cookies is discussed above.
Residents and citizens of the European Union are entitled to certain rights and privileges as defined in the European Union’s Global Data Privacy Rights regulation (GDPR). To the extent required by applicable law, we recognize you may exercise the following rights by contacting us at firstname.lastname@example.org:
Access: You may receive a list of your Personal Data we process.
Rectification: You may correct any Personal Data that we hold about you.
Erasure: You may request that we delete your Personal Data from our systems.
Data Export: We will send you a copy of your Personal Data in a common portable format.
Regulator Contact: You have the right to contact or file a complaint with regulators about our processing of Personal Data. To do so, please contact your local data protection or consumer protection authority.
It is possible for you to use some of our services without providing any Personal Data, but you may not be able to access certain features or view certain content. You have the following choices regarding the Personal Data we process, to the extent required by applicable law, which you may exercise by contacting us at email@example.com:
Consent: If you consent to processing, you may withdraw consent any time.
Direct Marketing: You have the choice to opt-out of processing related to marketing communications or to withdraw your consent if marketing communication was initiated through consent. You may exercise your choice via the links in our communications or by contacting us.
Profiling & Personalization: You may opt out of the creation or other processing of Preferences Data by automated means, and object to processing for personalization purposes. Note that we may not be required to cease certain types of processing based solely on an objection.
Behavioral Advertising: You may opt out or withdraw your consent to behavioral advertising. You can limit or opt out of our processing for behavioral advertising by contacting us. For third-party services, you must opt-out directly with the third party. Examples as shown below:
For Facebook Custom Audience Pixel, visit their customer support page.
For Twitter’s use of audience pixels, visit the Twitter help page.
For certain online advertisers, you can visit the Digital Advertising Alliance’s opt-out page at www.aboutads.info/choices or the Network Advertising Initiative at www.networkadvertising.org/optout_nonppii.asp.
As used herein and elsewhere on the Site, the terms “Southbridge,” “Inn at Southbridge,” “Southbridge Napa Valley,” “the Hotel,” “Site,” “us” or “we” refer to Southbridge and/or its subsidiaries or affiliates, and this website. The terms “user,” “you,” “your” or “customer” refer to the user or viewer of this Site or customer of the Hotel.
In addition to the use of your personal information for our business purposes, and subject to our not otherwise sharing or selling your data to Third Parties except as set forth above, Southbridge reserves the right to disclose your personally identifiable information as allowed or required by law and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process served on our Site. We may also access, preserve and share information when we have a good faith belief it is necessary to: detect or prevent fraud and other illegal activity; to protect ourselves, you and others, including as part of investigations; and to prevent death or imminent bodily harm.
If you have any questions about this policy, you can reach us at firstname.lastname@example.org.