HBX GROUP – Supplemental Privacy Notice for California Residents
Last updated: 29 May 2024
This Supplemental Privacy Notice for California Residents (“Supplemental California Notice”) describes how we collect, use, and disclose personal information relating to California residents, and the privacy rights available to them. If you are a California resident, this Supplemental California Notice applies to you. This Supplemental California Notice supplements the HBX Group’ Privacy Policy. Terms not defined in this Supplemental California Notice have the same meaning as in the CCPA.
1. Categories of Personal Information collected
The categories of personal information that we collect are described in Section 4. "What Personal Data Do We Process, For What Purpose and For What Reason" of our Privacy Policy. HBX GROUP may have collected the following categories of personal information within the last 12 months by reference to the statutory categories specified in the CCPA:
Identifiers, such as your name, email address.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as your contact information.
Professional information such as your business contact information and professional memberships.
Education information which would be provided on a Curriculum Vitae, such as schools attended, degrees awarded, and associated dates.
Protected classification information protected under California/federal law, including your gender or date of birth.
Commercial information, such as transaction information and purchase history.
Internet or network activity information, such as your browsing history and interactions with our Website.
Geolocation data, such as your approximate location based on your IP address.
Audio, electronic, visual, and similar information such as in a call recording if you were to contact our call centre.
Your account log-in information in combination with the password or credentials to access the account (if you are a B2B client or corporate contact that has an account with us); or your passport number, which may be considered as sensitive personal information under the CCPA.
2. Sources of Personal Information collected
The sources from which we collect personal data are described in Section 3. "How Did We Obtain Your Data?" of our Privacy Policy.
3. Business and Commercial Purposes of Personal Information collected
The business and commercial purposes for which we collect this data are described in Section 4. "What Personal Data Do We Process, For What Purpose and For What Reason" of our Privacy Policy.
The categories of third parties to whom we disclose this information for a business purpose are described in Section 5. "When and Why Do We Disclose Your Personal Data to Third Parties" of our Privacy Policy.
4. Retention of Personal Information
The length of time for which we retain personal information is described in Section 8. "For How Long Do We Keep Your Data?" of our Privacy Policy.
5. Sharing of Personal Information
HBX GROUP does not sell personal information as the term “sell” is traditionally understood (i.e. for money). However, the CCPA defines "sale" very broadly and includes the disclosure of a California resident's personal information in exchange for anything of value. Like most websites and apps, our Website and related online services use cookies and other similar technologies, as indicated in Section 3 of our Privacy Policy and as further described in our Cookies Policy. The use of cookies which makes available certain personal information relating to a California resident (such as their IP addresses and cookie IDs) to third parties, may be considered a “sale” or a “share” of personal information under the CCPA. You may opt out of such cookies at any time by adjusting your cookie choices in our cookie banner in accordance with the information provided in our Cookies Policy.
Identifiers,
Personal information categories listed in the California Customer Records statute
Professional information
Protected classification information protected under California/federal law
Commercial information
Internet or network activity information
Geolocation data,
Audio, electronic, visual, and similar information
We do not knowingly "sell" or "share" personal information of California residents who are under 16 years of age.
6. California Privacy Rights
If you are a California resident, you may have the following rights under the CCPA, subject to certain limitations and exceptions under applicable law:
Know and Access: You have the right to request to know and access the following information covering the 12 months preceding your request:
- the categories of personal information we have collected about you;
- the categories of sources from which your personal information was collected;
- the business or commercial purposes for collecting personal information about you;
- the categories of third parties with whom the business discloses personal information about you; and
- the specific pieces of personal information we have collected about you.
You have the right to receive your personal information in a portable and commonly used format.
Correct: You have the right to request that we correct any of your personal information that we have collected from you that is inaccurate.
Delete: You have the right to request that we delete personal information that we have collected from you.
Opt out of sales and sharing: To the extent our use of cookies and other tracking technologies to make available certain personal information to third parties constitutes a “sale” or “share” of personal information under the CCPA, you may opt-out of such “sale” or “share” at any time by adjusting your cookie choices in our cookie banner in accordance with the information provided in our Cookies Policy.
Limit the use and disclosure of sensitive personal information: We do not use or disclose “sensitive personal information”, as defined by the CCPA, for the purpose of inferring characteristics about you or in any way that would require a right to limit under the CCPA. As a result, we do not offer an ability to limit the use or disclosure of sensitive personal information.
Non-Discrimination: You have the right to not be discriminated against for exercising any of your CCPA rights.
Please also note that we will need to take steps to verify your identity before fulfilling any consumer request. As part of this verification process, you may be required to provide personal information such as your name and email address.
In California, an authorized agent may submit a rights request on behalf of a California resident. We may require the authorized agent to verify their authority to submit a request on your behalf, or we may require you to confirm with us that you provided the agent with permission to submit the request. We will only use the information provided for verification to confirm the requestor’s identity or authority to make the request, and for our compliance records.
California residents wishing to submit a verifiable request to exercise these rights can do so (up to twice within a 12-month period) by emailing us at dataprotection@hotelbeds.com. We will endeavor to respond to a verifiable request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period (up to a total of 90 days) in writing.
7. Shine the Light
California residents also have the right to request that we provide you with (a) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (b) the identity of those third parties. To exercise this right, contact us at the address below.
8. Notice of Financial Incentive
If we provide a financial incentive, we will provide you with the details, including how the incentive is related to your data before you participate so that you may make an informed decision about whether and how to participate. In the event you decide to take advantage of a financial incentive, you will always have the right to withdraw from participation and we will provide you with directions on how to do so.
9. Contact Us
If you have any questions about this California Privacy Notice or our handling of personal information, you can email us at dataprotection@hotelbeds.com with the subject line “Data Protection”, or by mail to HBX GROUP, to Camí Son Fangos, 100, Palma de Mallorca, Spain, indicating on the envelope the reference “Data Protection’.
