The Ritz-Carlton, Toronto

Privacy & Data Protection Policy

Kohano and InHouse World Limited (“We”) are committed to protecting and respecting your privacy.

This policy, together with our Terms of Use, sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.  Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting www.kohano.com you are accepting and consenting to the practices described in this policy. 

For the purpose of the Data Protection Act 1998 (the Act), the data controller is InHouse World Limited, 7 Henrietta Street, London, WC2E 8PS. 

Information we collect from you

We will collect and process the following data about you:

·        Information you give us: This is information about you that you give us by filling in forms on www.kohano.com (the Website) or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you apply for membership, search for a product or service, make a booking, enter a competition, promotion or survey and when you report a problem with the Website. The information you give us may include, but is not limited to, your name, address, gender, date of birth, e-mail address, phone number, financial and payment card information and information about government-issued documents such as passport and driving licence. It may also include the same information for your fellow travellers when making a booking that includes others. We may also collect information regarding correspondence with us including, but not limited to, emails and telephone conversations.

·        Information we collect about you: With regard to each of your visits to our site we will automatically collect the following information:

o  technical information, including, the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, location, time zone setting, browser plug-in types and versions, operating system and platform. 

o  information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer services. 

·        Information we receive from other sources: This is information we receive about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data if we intend to share those data internally and combine it with data collected on this site. We will also have told you for what purpose we will share and combine your data. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them, please see our Cookie Policy.

Uses made of the information

We use information held about you in the following ways:

·        Information you give to us: We may use this information:

o  to carry out our obligations arising from any bookings made with us and to provide you with the information about products and services that you request from us

o  to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about

o  to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you.

o  to notify you about changes to our service

o  to ensure that content from our site is presented in the most effective manner for you and for your computer

·        Information we collect about you: We will use this information:

o  to administer our site and for internal operations including troubleshooting, data analysis, testing, research, statistical and survey purposes

o  to improve our site to ensure that content is presented in the most effective manner for you and for your computer

o  to allow you to participate in interactive features of our service, when you choose to do so

o  as part of our efforts to keep our site safe and secure

o  to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;

o  to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.

·        Information we receive from other sources. We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

Disclosure of your information

You agree that we have the right to share your personal information with:

·        Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

·        Selected third parties including:

o  business partners, suppliers and sub-contractors for the performance of any bookings made with them

o  advertisers and advertising networks that require the data to select and serve relevant adverts to you and others.  We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience;

o  analytics and search engine providers that assist us in the improvement and optimisation of our sitec

o  credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.

We will disclose your personal information to third parties:

·        In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.

·        If InHouse World Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

·        If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms of Use or Terms and Conditions of Booking or other agreements, or to protect the rights, property, or safety of InHouse World Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Where we store your personal data

The data that we collect from you will be transferred to, and stored at, destinations inside and outside the European Economic Area (“EEA”). It will also be processed by staff operating inside and outside the EEA who work for us or for our suppliers. This includes staff engaged in, among other things, the fulfilment of your booking, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Membership details (username, password, etc) are personal and should not be divulged to others. Kohano will not be responsible for the use of membership where the Member has divulged their details to others. Members are responsible for the security of their membership details whether in physical form or stored electronically, this includes, but is not limited to, instances where the security of the Members’ electronic systems has been compromised. 

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Your rights

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise this right at any time by contacting us at customerservice@kohano.com.

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates.  If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.  Please check these policies before you submit any personal data to these websites.

Access to information

The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request will be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.

Changes to our privacy policy

Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

Contact

Questions regarding this Privacy Policy should be addressed to customerservice@kohano.com.