Viceroy Privacy Policy

Last Updated: September 4, 2025

1. Introduction

This Privacy Policy provides information about the privacy practices of Viceroy Hotel Management, LLC, its subsidiaries, and its affiliates (“we,” “us,” or “our”), including how we collect, use, disclose, and otherwise process personal information obtained through viceroyhotelsandresorts.com (the “Website”) in accordance with applicable law, including requirements under U.S. state comprehensive consumer privacy laws and the EU and UK General Data Protection Regulations. We may provide you with additional privacy notices, which supplement this Privacy Policy, at the point of collection of your personal information. We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the “Last Updated” date at the top of this Privacy Policy.

Viceroy Hotel Management, LLC, is the controller of personal information processed pursuant to this Privacy Policy. If you have questions regarding this Privacy Policy or our privacy practices, or otherwise would like to contact our DPO, you may email us at [email protected]. 
 

2. Personal Information Collected

Personal information means information that identifies or could reasonably be linked to an individual. Personal information includes terms like “personal data,” as defined by applicable privacy laws.

We, and our vendors, may collect personal information directly from you (such as when you book a room through the Website or contact customer service), through online technologies such as cookies, and from other third-party sources. 

The personal information collected about you may vary depending on the nature of your interactions with us, and includes the following categories:

• Identifiers. This includes names and contact information such as phone number, email address, and mailing address.
• Personal Records and Booking Information. This includes your signature, your booking dates, room number, and other reservation details.
• Protected Characteristics. This includes age, gender, nationality, citizenship, or disability status. This information is considered sensitive or special category data under certain laws.
• Internet or Other Electronic Network Activity. This includes Internet Protocol address, device identifiers, mobile network, operating system details, language preferences, referring URLs, length of visits, traffic data, pages viewed, and information regarding interactions with the Website.
• Geolocation Data. This includes approximate location, which may be based on your ZIP code or IP address.
• Audio, electronic, visual, or similar information. This includes photographs, audio recordings of customer service calls, and security video footage.
• Professional or Employment-Related Information. This includes your job title, employer, and other professional background information.
• Payment Information. This includes credit or debit card details and billing address information.
• Government Identifiers. This includes passport number, driver’s license information, or other government identifiers. This information is considered sensitive under certain laws.
• Inferences. We may draw inferences from the other categories of personal information we process to create a profile about you reflecting your preferences and interests.

3. Cookies and Other Similar Technologies

Types of Cookies We Use. We, and our vendors, may use cookies, web beacons, pixels, APIs, and other similar technologies (collectively, “Cookies”) to collect information when you interact with the Website. 

We categorize Cookies according to their general purpose and to illustrate the different functions they serve. Note that Cookie usage may vary, and some websites may use and categorize Cookies differently.

• Strictly Necessary Cookies (may also be referred to as “Essential” Cookies): These Cookies are required for the Website to operate. Strictly Necessary Cookies include, for example, those that secure the Website and administer your privacy preferences.
• Performance Cookies (may also be referred to as “Analytics” Cookies): These Cookies allow us to measure and improve the effectiveness of the Website. Performance Cookies include, for example, Cookies that count unique visits and traffic sources, identify which pages are the most popular, and map how visitors move around the Website. We may allow our vendors to set performance Cookies on the Website to support functions such as data analytics, Website user identification, and Website testing.
• Functional Cookies (may also be referred to as “Customization” Cookies): These Cookies allow the Website to support certain features, including personalization. Functional Cookies include, for example, Cookies placed by us or our vendors in response to user actions, including adjusting privacy settings, selecting a language, creating an account, or filling out forms. Vendors may also place functional Cookies and receive information from them to assist with online applications, webforms, and feedback or survey tools.
• Advertising Cookies (may also be referred to as “Marketing” Cookies): These Cookies may be set on the Website by us or our vendors. Advertising Cookies include, for example, Cookies that control the frequency of specific advertisements, assess the effectiveness of advertising campaigns, and help market to you while you are on our Website.
   

What Data We Collect Through Cookies and How We Use It. The information we or our vendors obtain about you may vary depending on the type of Cookie. For example, Cookies may collect usage information (such as the browser you are using, IP address and device identifier, length and time of visit, and pages visited), general geolocation data (to deliver content based on your location), and details about how you interact with the Website (including clicks, cursor movement, scrolls, and keystroke activity).

This information is used by us and our vendors for a variety of purposes, including to store your preferences and settings, enable you to sign in, analyze how the Website performs, track your interactions with the Website, develop inferences about you, deliver and tailor cross-context and/or interest-based advertising, combat fraud, and to fulfill other business purposes.

Duration of Cookies. Cookies vary in how long they are kept on your device. We use both Session Cookies and Persistent Cookies on the Website.

• “Session Cookies” are temporary Cookies that last for only a single browsing session. The information they collect is stored in temporary memory and erased shortly after you leave our Website or close your browser.
• “Persistent Cookies” are stored on your device until you take steps to remove the Cookies or until a particular Cookie’s expiration date (often several months after the Cookie is placed on your device). Persistent Cookies can record information from each visit you make to our Website as long as they remain on your device.

Our Cookie Vendors. Our Cookie vendors may include:

• Facebook. To change your settings with Facebook, login to your Facebook account and navigate to the Privacy Center at facebook.com/privacy/center or review your Ad Preferences at facebook.com/adpreferences.
• Google. We use Google Analytics, using which we implement Google advertising features such as dynamic remarketing, interest-based advertising, audience targeting, behavioral reporting, demographics and interests reporting, user segment analysis, device reporting, display advertising, video ads reporting, and impression reporting. For more information on how Google Analytics uses the data it collects, visit support.google.com/analytics/answer/6004245. To opt out of aggregation and analysis of data collected by Google Analytics, visit tools.google.com/dlpage/gaoptout. To adjust your Google advertising settings, visit adssettings.google.com.

We also may use social media technologies to conduct marketing campaigns. To change your privacy and advertising settings with a social media company, log in to your social media account and follow the instructions provided by the social media company.

We are not responsible for the effectiveness of external parties’ opt-out options or programs, or the accuracy of their statements regarding their programs. Note that opting out of these types of technologies may result in certain online features not functioning properly. In addition, using a tool to opt out of cross-context behavioral advertising may not opt you out of receiving contextual advertising.

We or our vendors may collect personal information about your online activities over time and across different devices and online websites when you access the Website.

Consent. Depending on your country of residence, a pop-up banner will appear when you first visit our Website where your consent is required for certain non-Essential Cookies. This banner provides options to accept all Cookies, reject non-essential Cookies, or adjust your Cookie settings/preferences. By accepting all Cookies, you consent to our use of Cookies, and all Cookies on the Website will be enabled unless you have independently disabled them through your browser settings.

You may withdraw your consent or change your Cookie preferences at any time by accessing the Website’s Cookie management tool. Depending on the current design of the Website, you may be able to access the Cookie manager through a link in the footer, a visible icon, or another similar link. You may also be able to use your browser settings to manage cookies and other similar technologies. In addition, advertising networks may offer you the ability to opt out of certain targeted online advertising. For more information about web browser Cookie settings, you may visit aboutads.info/choices, networkadvertising.org/choices, youronlinechoices.eu, or allaboutcookies.org.

4. How We Use and Disclose Personal Information

We use and disclose personal information for the following purposes:

• To provide services you request, including processing bookings and reservations; operating and maintaining our services; processing your payments and orders; communicating with you; and responding to your requests and questions.
• For security and integrity, including protecting against security threats; preventing, identifying, investigating, and responding to potential or actual fraud, illegal or malicious activities, and other risks; enforcing our policies and terms; and otherwise protecting our rights.
• For quality, safety, and internal research, including improving the quality of our services; assessing the Website’s performance; tracking and responding to technical issues; and developing new or enhanced products and service offerings.
• For advertising and marketing, including measuring Website usage; evaluating the effectiveness of our advertising and marketing; and leveraging insights to provide personalized experiences.

With respect to Government Identifiers, which may be considered sensitive under certain laws, we may use this information to verify your identity and for security and legal compliance purposes. Similarly, we may use Protected Characteristics, which may be considered sensitive or special category data under certain laws, for limited purposes (e.g., we may use disability information to provide appropriate accommodations).

We may disclose personal information:

• To our corporate affiliates, including for the business purposes detailed in this Privacy Policy.
• To strategic partners, including to business partners, sponsors, and in conjunction with co-branded partnerships.
• To vendors, including those that help us operate our business and the Website and/or perform services on our behalf, such as analytics, sending emails, serving advertisements, processing payments, promotion administration, customer service, and detecting and deterring fraud or other illegal activities.
• As part of a business transaction, including in the event we sell or transfer all or a portion of our business assets (e.g., further to a merger, reorganization, liquidation, or any other business transaction), including negotiations of such transactions.
• As required or permitted by law, including where we determine that disclosure of specific information is necessary to comply with the request of a law enforcement or regulatory agency or other legal process.

Our processing of personal information is carried out pursuant to the following legal bases:

• The processing is necessary for the performance of a contract with you, for example to provide you with the services and products you request.
• We have a legal obligation to process your personal information, such as to comply with applicable tax and other government regulations or to comply with a court order or binding law enforcement request.
• To protect your vital interests, or those of others.
• We have a legitimate interest in processing your personal information. For example, we have a legitimate interest in the following cases:
  • To analyze and improve the safety and security of our Website.  This includes implementing and enhancing security measures and protections and protecting against fraud, spam, and abuse.
  • To maintain and improve the Website.
  • To operate the Website and provide you with certain tailored advertising and communications to develop and promote our business.
  • To anonymize personal information and subsequently use the anonymized information.
• You have consented to the use of your personal information. When you consent, you can withdraw your consent at any time.

We do not disclose personal information obtained for text messaging purposes (e.g., mobile phone number, opt-in consent information) to third parties for those third parties’ own marketing purposes.

5. Promotions

You may provide personal information to us (or our vendors) to participate in contests, sweepstakes, and other promotions. Our use of your personal information for these promotions is subject to separate terms that are provided to you when you participate in the promotion.

6. DISCOVERY Loyalty Program

DISCOVERY loyalty program is a multi-brand guest loyalty program operated by the GHA. Participation in the Viceroy DISCOVERY loyalty program is subject to the GHA DISCOVERY Programme Terms & Conditions, and the personal information you provide for DISCOVERY loyalty program purposes is processed in accordance with GHA’s Privacy Policy.

7. Career Portals

The Website may include, or link out to, career portals powered by our vendors. These career portals allow you to submit job applications and other career-related personal information to us. These companies may provide separate terms and policies that govern their use of your personal information.

8. Other Online Services

The Website may contain links to, or features facilitated by, other online services. For example, we use vendor platforms to allow you to book reservations and to process your payment information. Or you may voluntarily choose to interact with a chat feature on the Website for customer service purposes. When you participate in interactive chats, either with a virtual or live agent, the contents of the chat may be captured and kept as a transcript. By using these features, you understand that our vendors may process the information obtained through the feature to provide the service on our behalf.

This Privacy Policy does not apply to the practices of companies that we do not own or control. If you choose to connect a third-party account to the Website, you should refer to that party’s privacy policy for information on how your personal information is collected, used, and protected.

9. Data Retention

We keep personal information for as long as is necessary for the purposes described in this Privacy Policy, or to achieve the purposes for which the information was collected, or as may be permitted under applicable law. This generally means holding the information for as long as one of the following apply:

• Your personal information is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected the information;
• Your personal information is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which the personal information was collected; or
• Your personal information is reasonably required to protect or defend our rights or property.

To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the data; the potential risk of harm from unauthorized use or disclosure of the data; the purposes for which we process the data and whether we can achieve those purposes through other means; and the applicable legal requirements.

10. Data Security

We maintain appropriate administrative, technical, and physical safeguards designed to help protect personal information collected or received through the Website. Although we use reasonable efforts to safeguard information, transmission via the Internet is not completely secure and we cannot guarantee the security of your information collected through the Website.

11. Privacy Rights

Depending on applicable law, you may have certain rights related to the personal information that we have collected about you.

You may exercise your privacy rights by submitting your requests to [email protected] or by calling +1-855-553-2323 (toll-free in the United States).

Rights that may apply to you are:

• The right to confirm that we process your personal information, know details concerning that processing, and to access your personal information.
• The right to obtain your personal information in a transportable format.
• The right to correct personal information that we maintain about you if you believe such personal information is inaccurate.
• The right to request deletion of personal information, subject to certain exceptions.
• The right to object to, opt out of, or restrict our processing of your personal information.
• The right to withdraw your consent to certain personal information processing.

We will comply with your request as soon as reasonably practicable, in accordance with applicable legal requirements. We will not discriminate against you for choosing to exercise any of your privacy rights.

To prevent unauthorized requests related to your personal information, we take steps to verify that you are the person that is the subject of the request. Following verification of your identity, we will process your request; if we are unable to fulfill your request, we will let you know why.

Depending on applicable law, you may have the right to designate an authorized agent to make certain privacy rights requests on your behalf. We will subject privacy rights requests we receive from agents to our verification process, which includes verifying the identity of the agent and their authorization to make the request.

If you have questions about how we process privacy rights requests, including re-examining requests we are unable to fulfill, you may contact [email protected].

12. Visitors Located Outside of the United States

We have centralized some of our data processing activities in accordance with applicable laws, and as a result, we may, directly or indirectly through our organization and affiliates, and through third-party entities around the world, process, store, and transfer the information you provide, including your personal information, as described in this Privacy Policy. Specifically, the information and personal information that we collect may be transferred to, and stored at, a location outside of your jurisdiction.

Your personal information may be transferred to and processed in the United States, or in other jurisdictions which may have data protection laws and regulations that are different from the laws in the country in which you are located. By submitting your personal information through the Website or at one of our properties, you agree to this transfer and processing.

We implement appropriate legal mechanisms and other safeguards to protect transferred personal information, and to ensure that an essentially equivalent degree of protection is applied to such personal information outside its country of origin. For further information about how we transfer personal information, please contact us by email at [email protected].

13. Contact Us

You may contact us regarding this Privacy Policy by emailing [email protected].