Privacy Policy

Sceptre Hospitality Resources
Privacy Policy

Introduction

Privacy is imperative to Sceptre Hospitality Resources (“SHR” or “we”). This Privacy Policy describes SHR’s web site and services (collectively, the “Service”). SHR (“SHR,” “we,” “us,” or “our”) and its wholly owned subsidiaries complies with the EU-U.S. and the Swiss-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the Swiss and the European Union to the United States. SHR has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit www.privacyshield.gov.

If you have questions, concerns, or believe there is an enforcement breech in regard to this Privacy Policy, you should contact our Privacy Officer at GDPR@shr.global.

Information Collection and Use

We collect the following personally identifiable information about our users: name, e-mail address, corporate web address, telephone number, business address, preferred means of communication, and other information voluntarily provided. This personally identifiable information is typically provided when users register for online services, subscriptions, communications, surveys, or to request information. We also collect information about users regarding web pages accessed, traffic patterns and site usage.

Cookies

Cookies are information components stored on your hard drive containing information about you. These pieces of information allow the Service to remember important information that will make your use of the Service more useful. You can choose to reject or turn off the cookies through your browser settings. If you reject or turn off the cookies, you may still use the Service.

Log Files

We use IP addresses to analyze trends, administer the Service, track users’ movements, and gather demographic information.

How We Use the Information We Collect About You

We, our service providers and our vendors may use any information collected by users: to operate the Service; to effect users’ transactions; to provide better services, products and opportunities to users; to notify users about services and opportunities that may be of interest to such users; to create and share reports about users’ transactions; and for other marketing purposes. We may also share your personally identifiable information with other third parties, including our business partners in order to continue to provide our services to you and only if business needs require it.

Email Confidentiality Policy

We have created this email Privacy Policy to demonstrate our firm commitment to your privacy and the protection of your information. The information in our e-mail and any attachment(s) is confidential and for the use of the addressee(s) only. If you received a mailing from us, (a) your email address is either listed with us as someone who has expressly shared this address for the purpose of receiving information in the future (“opt-in”), or (b) you have registered or purchased or otherwise have an existing relationship with us. We respect your time and attention by controlling the frequency of our mailings. We value your privacy and we use security measures to protect against the loss, misuse and alteration of data used by our system.

Security

We use security measures, such as firewalls, to safeguard the confidentiality of our users’ personally identifiable information. Information we collect about our users is stored on secured servers. However, “perfect security” does not exist. If you have any questions about the security of the Service, please send an e-mail to GDPR@shr.global.

Minors

Minors (individuals below the age of 18) are not eligible to use the Service and no portion of the Service is directed towards minors. We do not knowingly solicit any information about minors or market to minors.

Important Notices to Non-U.S. Residents/Privacy Shield Certification

SHR is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC). Additionally, SHR complies with the EU-US Privacy Shield and the Swiss-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union member countries and Switzerland to the United States. SHR has certified to the Department of Commerce that it adheres to the Privacy Shield Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Privacy Shield, and to view SHR’s certification, please visit https://www.privacyshield.gov.

However, it is important to note that the Platform and its servers are operated in the United States and elsewhere. If you are located outside of the United States, please be aware you’re your personal information will be transferred to, processed, and used in the United States and elsewhere. By using the Platform, you affirmatively consent to such transfer, processing, and use of your Personal Information in accordance with the EU-US Privacy Shield, the Swiss-US Privacy Shield, and this Privacy Policy. SHR accepts full accountability and responsibility for the protection of your Personal Information, according to the applicable privacy legislation and this Privacy Policy, during the course of these onward transfers to third parties.

Resolution of Complaints

In order to comply with the Privacy Shield principles, SHR commits to the resolution of complaints about your privacy and our collection or use of your Information. We have also committed to resolve any complaints pursuant to the Privacy Shield Privacy Principles by European Union and Swiss citizens, relating to this Privacy Policy and which cannot be resolved directly with our company, through a panel established by the EU and Swiss Data Protection Authorities (“EU DPAs”) as our Independent Recourse Mechanism (“IRM”).

If you have any questions regarding this Privacy Policy, please contact us as described in the “How to Contact Us” section below. We will investigate your question, respond to your inquiry, and attempt to resolve any concerns regarding your privacy question. If you do not receive acknowledgement of your complaint or, if your complaint is not satisfactorily addressed by SHR, then please contact us to be directed to the relevant DPA contacts. As further explained in the Privacy Shield Principles, a binding arbitration option will also be made available to you in order to address residual complaints not resolved by any other means. We have registered with the United States Council for International Business to cover the operating costs of the EU DPAs’ Dispute resolution panel.

SHR has further committed to cooperate with the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to the unresolved Privacy Shield complaints concerning data transferred from Switzerland.

Disclosure Required by Law

We cooperate with law enforcement agencies in identifying those who use the Service for illegal activities. Therefore, we respond to subpoenas, warrants or other court orders regarding information concerning any users. We will, at our discretion, disclose information if we believe that we are required to do so by law, that such disclosure is necessary to protect us from legal liability or that we should do so to protect the integrity of the Service.

Correction/Updating Personally Identifiable Information

Access to your personal information

You can ask to see the personal information that we hold about you. If you want to review, verify or correct your personally identifiable information, or if you no longer desire SHR’s services, we will endeavor to provide a way to correct, update or remove the data you provided to us. Please note that any such communication must be in writing by sending an e-mail to GDPR@shr.global. In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.

Your Consent; Notification of Changes

By using the Service, you consent to SHR’s collection and use of the information described in this Privacy Policy. If we decide to change this Privacy Policy, we will post those changes via our homepage so our users are aware of what information we collect, how we use it, and under what circumstances we disclose it. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will notify you by way of an e-mail. Please check this policy from time to time to make sure that you are aware of our latest Privacy Policy.

How to Contact Us Contact Information

Please direct any questions or comments about this privacy statement and our privacy practices to us at: GDPR@shr.global or Stabrizi@shr.global.

Last Updated June 4th, 2018.

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