Last Updated: May 2018
T&O Spine is committed to protecting the information that you share with us online, and explaining how we collect, process, and share that information. We provide you with the notice below in English only to avoid any misinterpretations caused by a language translation. If necessary, please seek the proper advice, or avoid use of this website.
Summary of Key Issues
|Collection||We collect Personal Information about you that you provide to us or that we obtain while you are using the Site.|
|Protection||We employ reasonable and current technical, administrative, and physical safeguards that are designed to prevent unauthorized access, maintain data accuracy, and designed to ensure correct use of Personal Information.|
|Use||We use Personal Information to provide you with services from our Site, to build features that will make the services available on the Site easier to use, to contact you about these services, and to send advertisements, marketing material or other offers that we think might be of interest to you.|
|Marketing and Choices||You have control on how we use Personal Information for marketing. You can exercise your control in any marketing communication.|
|Sharing||We do not share your data with any other 3rd parties.|
|Access and Data Subject Rights||We understand that you may want to change, access, or delete your Personal Information. You may do so by accessing your profile or by contacting us.|
|Children||Persons under the age of 16 are not eligible to use any services on our Site.|
|Contact Us||Should you have any questions, concerns or comments, please contact us.|
Personal Information We Collect About You
We collect your Personal Information on the Site to enhance the services we offer you, maintain and improve the Site, protect the security of you and our Site, comply with legal obligations, and inform you about other services and products that may be available through us, our affiliated companies, or through our marketing alliances. We collect Personal Information about you when you interact with or utilize services offered on this Site, such as:
- Creating a profile with us;
- Making reservations, accommodation requests and payments;
- Consenting to marketing communications;
- Applying for a job;
- Submitting comments, reviews, or other user-generated content;
- Connecting or interacting with us through social networks (e.g., Facebook, Google+, Twitter); or
- Requesting customer or technical support.
Personal Information includes:
- Postal or billing address;
- E-mail address;
- Telephone or mobile number;
- Payment card information;
- Government identification (e.g., passport identification to verify traveler identities);
- Location via IP address;
- Device being used (for our mobile site);
- Cookies and similar technologies;
- Member hotel stay information;and
- Other relevant data.
Even if you do not provide us with any Personal Information, we collect certain non-personal information about how you use our Site. This information cannot identify you and is used for statistical purposes only.
Use and Sharing of Personal Information
We only process and share your Personal Information, including sharing with service providers or other external entities, to the extent reasonably necessary to fulfill your requests and meet our legitimate business and legal objectives. When we disclose Personal Information to external entities to perform services for us, we establish by contract that they may access your Personal Information only for the purposes of performing those services. We may also use what we know about you to offer you other products and services. We may combine your online information with information collected from offline or online sources, or information we already have. We may also use and disclose certain Personal Information to our affiliated companies and others for any purpose allowed by law.
We generally process and may disclose your Personal Information to others to:
- Provide you with products and services, including authenticating authorized users, and marketing our products and services;
- Perform certain services or other transactions initiated by you;
- Respond to your questions, complaints, or reviews of our product or services;
- Send you communications about online transactions, product information, ads and promotions, electronic newsletters, or other notices you requested or offers tailored to you;
- Enable our advertisers, where appropriate, to provide you with more personalized content, and track the effectiveness of certain advertising campaigns;
- Comply with applicable law, obey judicial orders, cooperate with law enforcement authorities, or prevent any suspected illegal activities;
- Help us run our business; or
- For any other everyday business purposes, such as product development and Site administration.
Processing Basis and Consequences
- Necessary to provide information or otherwise carry out the performance of a contract with you as an individual;
- Our legitimate interests, including:
- Customer relationship management and other forms of marketing and analytics;
- Fraud prevention, misuse of company IT systems, or money laundering;
- Physical, IT, and network perimeter security;
- Internal investigations; and
- Intended mergers and acquisitions.
- Compliance with legal obligations and/or defense against legal claims, including those in the area of labor law, social security, and data protection, tax, and corporate compliance laws.
- Protection of the vital interests of any individual;
- Performance of a task carried out in the public interest or in the exercise of official authority vested in us; and
- Consent, as permitted by applicable law.
Providing us with Personal Information is voluntary, but your refusal to provide Personal Information for the above-mentioned purposes may affect our ability to fulfill our contractual obligations.
Your Rights Concerning your Personal Information
You have the following choices regarding our use and disclosure of your Personal Information:
- Marketing Communications. If you no longer wish to receive any marketing communications, remain on a mailing list to which you previously subscribed or receive any other communication from us, please follow the unsubscribe link in the relevant communication. Even after you opt-out or update your marketing preferences, we may still contact you for transactional or informational purposes. These include, for example, customer service issues, surveys, or any questions regarding a specific reservation.
- Cookies and Similar Technologies. Please review your browser or computer settings for certain cookies and see below to exercise certain choices regarding cookies.
Europe and certain other non-US jurisdictions maintain local data protection regulations that confer certain data protection rights on individuals. If applicable, and you wish to exercise any of these rights, please contact us as set out below.
- Right of access: You have the right to obtain from us confirmation as to whether or not Personal Information concerning you is processed, and, to request access to the Personal Information. The access information includes, among other things, the purposes of the processing, the categories of Personal Information concerned, and the recipients or categories of recipient to whom the Personal Information have been or will be disclosed. This is not, however, an absolute right, and the interests of other individuals may restrict your right of access. You may have the right to obtain a copy of your Personal Information undergoing processing.
- Right to rectification: You have the right to obtain from us the rectification of inaccurate Personal Information about you. Depending on the purposes of the processing, you have the right to have incomplete Personal Information completed, including by means of providing a supplementary statement.
- Right to erasure (right to be forgotten): Under certain circumstances, you have the right to obtain from us the erasure of Personal Information concerning you, and we may be obligated to erase that Personal Information.
- Right to restriction of processing: Under certain circumstances, you have the right to obtain from us restriction of processing your Personal Information. In that case, your data will be marked and may only be processed by us for certain limited purposes.
- Right to data portability: Under certain circumstances, you have the right to receive the Personal Information about you, which you have provided to us, in a structured, commonly used and machine-readable format, and you have the right to transmit that data to another entity without hindrance from us.
- Right to object: Under certain circumstances, and at any time, you have the right to object, on grounds relating to your particular situation, to the processing of your Personal Information by us, and we can be required to no longer process your Personal Information.
Where permitted by applicable law, you also have the right to lodge a complaint with a competent data protection supervisory authority.
Security of Your Information
We maintain reasonable technical, electronic, and organizational security procedures to maintain the security of Personal Information, and safeguard Personal Information against unauthorized or unlawful processing and/or against accidental or unlawful loss, alteration, disclosure or access. Our security procedures include contractual terms with any contractors, agents or data processors that require such entities to protect the security and confidentiality of Personal Information in accordance with our standards. While we strive to protect your Personal Information, we cannot ensure the security of the information you transmit. It is your responsibility to safeguard any email or password that you have created or used in connection with any service or site and to notify us if you ever suspect that the security and confidentiality of such email or password has been compromised in any way.
Retention and Storage of Your Information
We will maintain Personal Information for as long as we are required to do so by applicable law(s), or for as long as necessary for the purpose(s) described above for which it is processed. We will delete Personal Information when it is no longer needed and/or take steps to properly anonymize it so that you can no longer be identified from it (unless we need to keep your information to comply with legal or regulatory obligations to which we are subject) and, in any case, upon expiration of the maximum storage term set forth by applicable law.
We do not knowingly collect Personal Information from children under the age of 16, and users under the age of 16 should not submit any Personal Information to us. If we have actual knowledge that Personal Information about a child under 16 years old has been collected, then we will take the appropriate steps to delete this Personal Information.