Putahracsa Policy on Privacy of Guest Personal Information

For the purposes of policy, personal information means information about an identifiable individual, exceeding what is normally on a business card or in a telephone book, i.e. name, title, business address or telephone number. Any reference to a Guest within this policy is in reference to personal information and not business information.
Putahracsa has implemented policies and procedures to give effect to the principles, including:

1. Implementing procedures to protect personal information.

2. Establishing procedures to receive and respond to complaints and inquiries in connection with the collection, use and disclosure of personal information by Putahracsa.

3. Training staff and communicating information to staff about Putahracsa’s policies and procedures.

4. Developing information to explain Putahracsa’s policies and procedures to Guests.
These principles are explained in more detail below:

Identifying Purpose
Putahracsa will identify and document the purposes for which it collects personal information. Only personal information that is necessary for those identified purposes will be collected. If Putahracsa intends to use the personal information that has been collected for a new purpose, this new purpose will be identified and consent for such new purpose will be obtained from the Guest to which the personal information relates prior to using such personal information.
Putahracsa shall only collect, use and disclose personal information about Guests for the following purposes:

1. To facilitate return visits and, wherever possible, to meet guests' personal preferences.

2. To advise guests of goods and services by or by arrangement with the company.

3. To improve the offering of goods and services to guests.

4. To assist Putahracsa in the collection of fees and other charges owing with respect to services rendered by Putahracsa.

5. To assist Putahracsa in revenue management with respect to the Resort.

6. To assist Putahracsa in communication with users of the Resort for the purpose of promoting the use of the Resort.

7. To assist an entity with whom Putahracsa has an agreement relating to the collection of fees and other charges in connection with the use of the Resort.

Putahracsa does not sell or trade personal information about guests to any third party agencies.

Consent
The knowledge and consent of Guests is required for the collection, use or disclosure of personal information, except when inappropriate, including where permitted or required by law. Putahracsa will seek consent for the collection of personal information at the time of collection, wherever possible.

Putahracsa will make a reasonable effort to ensure that Guests are advised of the purposes for which the personal information being collected will be used, and will state the purposes in a manner that will allow Guests to reasonably understand how their personal information will be used or disclosed by Putahracsa.

Consent may be obtained in a variety of ways, for example, through contracts and registration forms, orally by telephone or by electronic media, depending on the circumstances and the type of personal information being collected, and in particular, on the sensitivity of the personal information. The reasonable expectations of Guests will be considered when obtaining consent. For example, where Guests provide their names and addresses for mailing and billing purposes, they should reasonably expect that this information would also be used for sending out Guest Satisfaction Surveys, where the choice to respond is the Guests'.

In certain circumstances, personal information can be collected, used or disclosed without the knowledge or consent of the Guest. For example, legal, medical or security reasons may make it impossible or impractical to seek consent. Seeking consent my be impossible or inappropriate when there is an emergency threatening the Guest's life, health or security, or where the Guest is a minor, seriously ill or mentally incapacitated.

Although information may be publicly available, Putahracsa may provide personal information to its lawyers, advisors, agents and/or third parties to collect a debt, comply with a subpoena, warrant or other court order, to a government institution requesting the information upon lawful authority, or as may be otherwise required by law. In all cases, proper internal authorization for disclosure procedures will be followed.

The use of Putahracsa will be considered consent to collect, use and disclose personal information for stated purposes.

Copies of the Putahracsa Privacy Policy will be published on the Putahracsa Website at www.putahracsa.com.

Consent may be withdrawn by a Guest by providing reasonable notice to Putahracsa to the Privacy Officer. Putahracsa will inform the Guest of any implications of such withdrawal. Any withdrawal of consent will still allow Putahracsa to use and disclose a Guest's personal information in order to collect or enforce payment of amounts owing as a result of a Guest's previous or continuing use of the Resort.
Subsequent use of the Resort will automatically provide consent for the collection, use, disclosure and retention of personal information.

Limiting Collection
The collection of personal information will be limited to that which is appropriate in the circumstances.
Putahracsa collects some information about prospective guests using technology, so it may not be readily apparent to prospective guests that it is being collected. For instance, when a prospective guest comes to our site a prospective guest's IP address is collected so that we know how many visits we have had by separate individuals. An IP address is often associated with the place from which a prospective guest enters the Internet like their Internet Service Provider (ISP), their firm or company or their university. This information is not personally identifiable.

Putahracsa may use "cookie" technology to obtain non-personal information from its online visitors for certain purposes. The cookie is stored on their computer to allow them to get back into certain areas of the website with as minimal delay as possible. We do not extract personal information in this process nor do we disclose this information. Cookies are a tool to allow us to update and improve our sites.

Limited Use, Disclosure & Retention
Putahracsa will not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the guest or as required by law. Personal information cannot be used or passed on in a manner inconsistent with the identified purpose.
Putahracsa may disclose a Guest's personal information to third parties retained by Putahracsa for the purposes of billing such a Guest for the use of Putahracsa and to collect and enforce payment of amounts owing by such Guests.

Certain Putahracsa employees and third party agents may be given access to a Guest's personal information collected by Putahracsa in so far as their duties require access for the purposes outlined. Putahracsa employees and such third party agents are governed by a non-disclosure agreement prohibiting disclosure or use of any confidential or personal information for any purposes other than the stated purposes.

Personal information that has been used to make a decision about a Guest will be retained in accordance with the Putahracsa document retention guidelines. Personal information that is no longer required will be destroyed, erased or made anonymous. Putahracsa retains personal information of a Guest only for as long as it is required for Putahracsa’s business purposes or as required by federal and provincial laws.

Accuracy
Putahracsa will take reasonable steps to ensure that the personal information under its control is as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.
Putahracsa will not routinely update personal information, unless such a process is necessary to fulfill the purposes for which the information was collected. Putahracsa will take reasonable steps to ensure that personal information that is used on an ongoing basis, including personal information that is disclosed to third parties, is accurate and up-to-date.

Access to a Guest's personal information on record with Putahracsa may be requested by that Guest in order to review and amend their personal information, as appropriate. In circumstances where personal information has been provided by a third party, Putahracsa will refer the Guest to that party. It is the responsibility of the third party to maintain accuracy of the personal information that is provide by them. To access your personal information, refer to "How to contact us".

Safeguards
Putahracsa will take reasonable steps to protect personal information through security safeguards appropriate to the sensitivity of the personal information. Team Members of Putahracsa who have access to personal information will be made aware of the importance of maintaining the confidentiality of personal information. Security safeguards protect against loss or theft, as well as unauthorized access, disclosure, copying, use or modification.

Openness
Putahracsa will make readily available to Guests specific information about its policy and guidelines relating to the management of personal information.

Putahracsa will be open about its policy and procedure with respect to the management of personal information, and Guests will be able to acquire information about these policies easily and in a form that is generally understandable. This policy and any related information is available at all times on the Putahracsa Website, www.putahracsa.com under Privacy. To contact putahracsa, refer to "contact us".

Individual Access
Putahracsa will inform a Guest of the existence, use and disclosure of their personal information (including to third parties) and will provide access to that personal information, upon written request. Putahracsa will assist a Guest in the preparation of a request for access when such a Guest requests assistance. Putahracsa will inform the Guest whether or not it holds personal information about them, and will indicate the source of any such personal information, when possible.

There may, however, be situations in which Putahracsa will not be able to provide access to all the personal information that it holds about a Guest, although these situations will be limited and specific, and permitted or required by law. For example, Putahracsa will not be able to provide access to a Guest's personal information where giving such access would likely reveal personal information about a third party, unless that third party's personal information can be severed from the Guest's personal information. If Putahracsa refuses a request for access, the Guest will be informed in writing of the refusal, setting out the reasons for the refusal and informing the Guest of their recourse.

Putahracsa will require that Guests requesting access to their personal information will provide the appropriate verification information required to obtain access to such personal information. This information will not be used for any purpose other than to permit Putahracsa to provide an account of the existence, use and disclosure of the Guests' personal information.

Putahracsa will be as specific as possible in providing an account of third parties to which personal information has been disclosed, and will provide a list of organizations to which personal information may have been disclosed when it is not possible to provide a list of the organizations to which specific personal information have actually been disclosed.

Putahracsa may charge a reasonable fee for responding to a request. This fee will be determined based on the request and any request specific administrative or system costs that may be incurred, and will advise the Guest, in advance, of the approximate cost. The personal information requested would be provided in a form that is generally understandable.

A Guest will be able to challenge the accuracy and completeness of the personal information and have it amended as appropriate. Depending upon the nature of the personal information challenged, amendment may involve the correction, deletion or addition of information, and the amended information will be transmitted to third parties having access to the personal information, where appropriate.

Challenging Compliance
Putahracsa will inform Guests who make inquiries or lodge complaints of the existence of the relevant complaint procedures. Putahracsa will investigate all complaints, and if a complaint is justified, Putahracsa will take appropriate measures, including amending policies and procedures.

How to contact us:
If you have any questions or comments about this Privacy Policy or you feel that your concerns or complaints have not been resolved to your satisfaction, please contact us:

     Tel : +66(0)2 250-4527-9
     Fax :+66(0)2 250-4525
    info@putahracsa.com

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