This notice describes the general privacy policy of Apes Hill (Barbados) Inc. (“Apes Hill”, “our”, “we” and “us”) and sets out the basis on which Apes Hill will handle your information and the basis upon which Apes Hill will use, process, store or disclose any information including the personal information set out below relating to you (“Personal Information”) that will be collected by Apes Hill or that is provided by you through the Apes Hill website, www.apeshill.com. Any information provided by you will be held by Apes Hill as a data controller.

Apes Hill collects your information to operate effectively and provide you with the best experiences with our services. The specific kind of information collected will depend on the context of your interactions with Apes Hill, and the services you use. The following are examples of the information that may be collected:

1. Contact information – such as name, email address, mailing address and telephone number;
2. Payment information – including credit card numbers and billing address;
3. Demographic data – such as age, gender, country and preferred language;
4. Information related to your reservation, stay or visit to our property;
5. Copies of your correspondence if you contact us;
6. Your interests and preferences;
7. Information collected through the use of closed-circuit television systems, card keys and other security systems; and
8. Information related to your use and interaction with our website.

There may be instances in which the Personal Information you provide to us or that we collect is considered sensitive personal information under the privacy laws of some jurisdictions (e.g. biometric data, credit card information, location data depending on the definition of sensitive personal information under the relevant jurisdiction). We only process sensitive personal information in your jurisdiction if and to the extent permitted or required by applicable law (e.g. so that we ensure we tailor our services to you, to ensure we can process credit card payments).

 We collect the above information in a variety of ways, including:

1. Information You Give Us: We receive and store information you enter our website or give us in any other way, including for example, when you stay as a guest at our property. You decide how much information to share with us in most cases, but not sharing required information may limit your ability to engage in certain activities, such as payment information required to complete your reservation. If you submit any personal information relating to another person, you represent that you are authorised by that person to do so and to permit us to use the information in accordance with this Privacy Policy. You also represent that the information you provide is accurate.
2. Automatic Information: When you use or interact with our website and/or use any apps that we may make available on our website, we receive and store information generated by your activity and information automatically collected from your browser or mobile device. For example, like many websites, we obtain certain information when your web browser accesses our website including your IP address, browser type, operating system, mobile network data, pages viewed and access times. This information helps us to communicate with our customers and better understand them.
3. Security Systems: When you visit our properties, information may be collected about you through such properties’ closed circuit television systems, electronic key cards and other security systems.
4. Information from Other Sources: We may receive information about you from other sources, such as public databases, joint marketing partners, and other third parties. This may include information from your travel agent, airline, credit card, and other partners.
5. Age Limitations: Apes Hill does not knowingly collect personally identifiable information from our websites from any person under the age of 18. Apes Hill may collect personally identifiable information from people under the age of 18 as part of the guest registration process, but always with the consent of such person’s parent or guardian.

Apes Hill collects your information to operate effectively and provide you with the best experiences with our services. Apes Hill may collect, use, and disclose the information it collects for a variety of reasons, including for the following purposes:

1. Fulfilment of Reservation and Other Purchases: We may process information relating to transactions that you enter into with us and/or through our website ("Transaction Data"). The Transaction Data may be processed for the purpose of completing your room reservation, supplying the purchased goods and services, customising our services to your preferences, seeking your feedback on your stay at our properties, and keeping proper records of those transactions.
2. Membership Programs: To administer and operate voluntary membership programs, including loyalty programs and frequent flyer programs. The data may be processed for the purposes of recording stay and transactional data, earning and redeeming rewards, points, or credits in connection with the programs.
3. Response to Inquiries: We may process information contained in or relating to any communication that you send to us ("Correspondence Data"). The Correspondence Data may include the communication content and metadata associated with the communication. The Correspondence Data may be processed for the purposes of communicating with you and record-keeping.
4. Internal Business Purposes: For our internal business purposes, such as data analysis, audits, developing new products, enhancing the website, improving our services, identifying usage trends and visiting patterns, determining the effectiveness of our promotions, and meeting contractual obligations.
5. Administrative and Other Communications: To send you important information regarding our website, changes to our terms, conditions, and policies, or other administrative information (e.g., information about your travel reservations, such as reservation confirmations).
6. Marketing and Promotions: To communicate news and promotions to you relating to Apes Hill-related products and services and other products and services we think may be of interest to you, and to operate sweepstakes, contests, or other marketing or promotional activities.
7. Safety and Security: To maintain your safety and security as well as that of other guests and personnel, while you visit our properties.
8. Our Legal Duties: To comply with legal and regulatory requirements or demands in accordance with applicable law, a court order, subpoena, or other legal process.
9. Additional Uses: We may also use your data in other ways as described to you when you provide such information to us.

The legal basis for processing your personal information is made up of one or more of the following reasons depending on the circumstances: (i) your consent, and/or (ii) providing the services you have requested, and/or (iii) legitimate interests, and/or (iv) compliance with applicable laws, regulations, court orders or other legal process.

Apes Hill uses tracking tools like browser cookies and web beacons to collect information from you. We collect information about users over time when you use this website or any apps that we may make available on our website. We may have third parties collect personal information this way. Learn more about these tools and how you can control them here.

As a company with the global geographical diversity of our business, it is essential that we share information with other parties in order to provide you with and to maintain the best possible service. The specific kind of information we share will depend on the context of your interactions with Apes Hill, and the services you use. Accordingly, your personal information may be shared with the following parties insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy:

1. to any affiliates of Apes Hill and other organisations which own the hotels and residences managed by us; to the representative or travel advisor that has supplied us with your personal information (for example, your travel agent, personal assistant, employer or spouse who has provided us with your details). The name and contact details of such representative or travel advisor will differ on a case-by-case basis. Please contact your representative or travel advisor for any questions relating to the processing of your personal information by such representative or travel advisor;
2. to third parties not affiliated with Apes Hill when we have your consent to do so;
3. to our trusted business partners to process it for us, based on our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures;
4. to our marketing and advertisement partners to provide you with more relevant ads on our site and to encourage you to return to our site;
5. to third party service providers (such as Facebook or Google) to (i) provide us with analytics so we can evaluate and improve our products and services, (ii) to help us identify existing and potential guests and customers similar to our audience, and (iii) help us to segment and understand our audience by providing additional information so that we can send the most relevant and targeted communications possible;
6. to organisations that own, manage or operate the spas, restaurants, health clubs, and other outlets at our properties so they can provide their services;
7. to third parties not affiliated with Apes Hill if we have a good-faith belief that it is reasonably necessary to: (1) meet any applicable law, regulation, legal process or enforceable governmental request; (2) enforce applicable terms of service, including investigation of potential violations; (3) detect, prevent, or otherwise address fraud, security or technical issues; and (4) protect against harm to the rights, property or safety of Apes Hill, our users or the public as required or permitted by law; and
8. to any third parties to the extent necessary with respect to a sale of all or part of our business operations or assets.

The Personal Information which is collected from by you by Apes Hill may be transferred to, and stored at, a jurisdiction outside of Barbados and may be transferred outside of the European Economic Area. Should such a transfer occur, it is the policy of Apes Hill that:

1. the data transfer does not occur without the prior written approval of Apes Hill; and
2. an appropriate transfer agreement is executed to protect your Personal Information.

Such data transfers may be to a country or territory which may not provide for the same level of privacy protection as that provided by the country or territory in which the information was collected, but Apes Hill will take all reasonable steps to ensure that while your Personal Information is within the control of Apes Hill, Apes Hill will handle your Personal Information using reasonable security and confidentiality procedures to keep your Personal Information secure and confidential.

If you are located in the European Union, this section sets out the rights which are applicable under the General Data Protection Regulation.

Should you wish to exercise any of the abovementioned rights, kindly submit a written request to our Data Protection Officer at data-protection@apeshill.com

Apes Hill will provide you with the requested information on any action taken upon your request in relation to any of the abovementioned rights as soon as practicable and no later than thirty (30) business days of receipt of such a request. The time within which the request is processed by Apes Hill may be extended to forty-five (45) business days if required. Apes Hill will advise you, in writing, if such an extension is required. Apes Hill will require you to verify your identity when seeking to exercise any and all of your privacy rights.

You have the right to lodge a complaint with your privacy or data protection authority in the European Union.

The security of Personal Information is of paramount importance to Apes Hill. Apes Hill will implement reasonable administrative, organisational and technical safeguards and security measures to protect your Personal Information within our control from unauthorised access, acquisition, disclosure, destruction or alteration, accidental loss, misuse or damage. Apes Hill regularly reviews and monitors such safeguards and security measures.

To the extent permissible by applicable law, Apes Hill will retain your Personal Information for such period as necessary to satisfy or to fulfil the following:

1. the purposes for which that Personal Information was provided,
2. an identifiable and ongoing business need, including record keeping,
3. a specific legal or regulatory requirement, and/or
4. a requirement to retain records that may be relevant to any notified regulatory investigations or active legal proceedings.

Where there is no sufficient justification to retain such personal information, such Personal Information will be safely and securely deleted, disposed of, anonymised and/or, where permitted by applicable law, blocked.

Our Data Protection Officer will be happy to answer any concerns or queries you may have relating to the use or storage of your Personal Information. Your principal rights (depending on applicable law) include: (a) the right to access; (b) the right to rectification; (c) the right to erasure; (d) the right to restrict processing; (e) the right to object to processing; (f) the right to data portability; (g) the right to complain to a supervisory authority; (h) request that the rules on processing of your personal information are explained and (i) the right to withdraw consent. You may exercise any of these rights in relation to your personal data by contacting our Data Protection Officer. Our Data Protection Officer can be contacted by email at data-protection@apeshill.com or by post at The Data Protection Officer, Apes Hill (Barbados) Inc., Apes Hill, St. James, Barbados.

The linking of third-party websites to this website does not indicate any association with or endorsement by Apes Hill. Apes Hill does not assume responsibility or liability of any nature whatsoever for the activities conducted or information contained in the third-party websites.

This privacy policy will be subject to change from time to time. The effective date of this current privacy policy is set out at the end of this document. Your use of this website, www.apeshill.com, constitutes your acceptance of the current terms as set out in this privacy policy.