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Last Updated March 16, 2020

The Palms Hotel & Spa (“The Palms,” “we,” “us,” “our”) takes privacy matters seriously. This Privacy Policy describes the types of information we collect from and about you when you visit thepalms.com, circa39.com (the “Websites”); The Palms Hotel & Spa, Circa 39 Hotel, or other properties that we own; or otherwise interact with us (together, the “Services”). This Privacy Policy also explains how we may use or share your information, and your choices about that use.

When you use the Services, or share your information with us, you agree to let The Palms use your information as described in this Privacy Policy. You also agree to our Terms of Use. If you do not agree, please do not use the Services.


This Privacy Policy covers:

  1. Types of Information We Collect
  2. How We Collect Your Information
  3. How We Use Your Information
  4. How We Share Your Information
  5. Your Choices
  6. Choices Under the General Data Protection Regulation
  7. Choices Under the California Consumer Privacy Act
  8. How We Protect Your Information
  9. Links to Other Sites
  10. Children’s Privacy
  11. Privacy Policy Changes
  12. Transferring Data Abroad
  13. Governing Law
  14. Contacting The Palms

1. Types of Information We Collect

When you use our Services, we collect different types of information from and about you. This information includes:

  • Identifiers: Information that identifies you directly.
    • Examples: Full name; email address; phone number; billing address; your IP address, and other data associated with your online activity.
  • Commercial Information: Information about your reservations or purchases.
    • Examples: Reservation dates and times, room accommodation requests, room number, spa services purchased, purchase history.
  • Online Activity: Limited information about how you use our Services.
    • Examples: How you found our website (e.g., advertisements, search engines, bookmarks); how you interact with our website (e.g., pages you view on our site); the type of device and browser you’re using.
  • Geolocation Information: Information about where you are when you use the Services.
  • Financial Information: Information about your payment methods with us, if applicable.
    • Examples: Tokenized credit/debit card numbers.
  • Inferences: Information we can determine or estimate about you based on information we collect about you.
    • Examples: Purchase preferences, potential interest in specific services we offer.
  • User-Generated Content: Information you post on or about the Services.
    • Examples: Comments or reviews about the Services.

2. How We Collect Your Information.

We collect the information described above from different sources. Sometimes, we collect information from you directly. Other times, we collect information from third parties. The following explains a little more about how we collect this information.

  • Information You Give Us. If you make a reservation through our Services, make a purchase, fill out a survey, sign up for emails, or enter a contest, you give us identifiers and other information about you. Sometimes, you can choose not to give us information. For example, you don’t have to sign up for emails. But other times, we’ll need your information to be able to provide you with the Services. For example, we need your billing information when you make a reservation.
  • Information We Collect Automatically. When you use our Services, we automatically collect some information, such as identifiers, geolocation information, commercial information, online activity, and inferences. We collect some of this information using cookies or web beacons. These are small data files that your computer stores with information about your online activity and how you use the Services. Sometimes we collect this information from your browser to help improve your experience with the Services. You may have options to change your browser settings to choose how we can collect some of this information.
  • Information from Non-Affiliated Entities. If you use a separate service (e.g., an online travel agency) to make reservations with us, that service gives us information that we need to serve you. We also may obtain information from third parties to better understand your interests. We use such information consistently with this Privacy Policy. However, our data sources maintain their own policies regarding the processing of personal information, which we do not control.

3. How We Use Your Information

We use identifiers, commercial information, online activity, geolocation information, user-generated content, and financial information we collect for the following business purposes:

  • Tailoring Your Experience with the Services
  • Fulfilling Your Reservations
  • Customer Service
  • Getting Your Feedback
  • Improving Our Services
  • Maintaining Security and Preventing Fraud
  • Processing Payments for the Services.

We use identifiers, commercial information, geolocation information, online activity, and user-generated content for the following commercial purposes:

  • Contacting You with Offers or Promotions
  • Marketing and Advertising
  • Processing Your Entry in a Contest or Promotion

We also use the information we collect through the Services for other purposes, with your consent. We may not always ask for your permission when we use user-generated content for advertising purposes. We recommend being careful not to post any sensitive or confidential information in user-generated content.


4. How We Share Your Information.

We share the information we collect with different third parties for different purposes. We share identifiers, commercial information, and limited online activity with the following third parties:

  • Advertising Partners. To provide you with relevant advertising. We also provide select advertising partners with either personal information, aggregate or anonymous information (that does not identify you), or both to provide you with relevant advertising, or to limit the advertising you see on other sites or apps.
  • Analytics Providers.We use Google Analytics to better understand how you use our Services. For more information, click here.
  • Storage Providers. To store the information we may collect about you.
  • Service Providers. To help with promotions, Service design, and conducting surveys.
  • Affiliates and Subsidiaries. To streamline your reservations across our properties.

We share identifiers and financial information with the following types of entities:

  • Payment Processors. To help process your payments.
  • Storage Providers. To store the financial information we collect about you.

When you post user-generated content to our site, other users will be able to see that information. Please use care in determining what information to post to our site; we do not control how others use this information.

We may share your information with another business if we choose to sell, buy, or otherwise reorganize our business. We may also share your information in response to lawful demands and to comply with applicable laws. We may also share your information with other third parties, when you have given your consent.


5. Your Choices

You have some choices about how we collect or use your information. The following explains some of those choices.

  • Do Not Track Mechanisms. Your browser may give you the option to turn on a “Do Not Track Signal.” There is no industry consensus on the meaning of these signals, and the Services do not respond to them.
  • Emails. You can unsubscribe from, or change your preferences for, our marketing emails. To do so, click the unsubscribe link at the bottom of our marketing emails. Even if you unsubscribe, we may still send you some informational emails. For example, we will send you emails about reservation you make or to notify you of updates to our Privacy Policy or Terms of Use.
  • Third-Party Opt-Outs. When you use our Services, we sometimes place (or third parties place on our behalf) cookies to show you relevant advertising, including when you’re visiting other sites. You can click here to limit how your online activity information is shared with us or other websites. Not all third parties participate in this opt out mechanism. These opt outs only applies to the device and browser that you are using when you opt out, so you will have to repeat the process for each of your devices or when you use a different browser.

If you want to stop Google Analytics from collecting information about your visits, you can download the browser add-on available here. The Palms will still receive some information about your use of the Services.


6. Choices Under the General Data Protection Regulation.

The European Union’s General Data Protection Regulation provides certain rights with respect to personal information, including the right to access, correct, restrict the processing of, or delete personal information previously provided to The Palms. We extend these rights to all of our consumers, no matter where they reside. This can be done by submitting a request to privacy@thepalmshotel.com, identifying which right you are requesting. We will only respond to these requests if we can identify matching records (email address or mailing address) on our systems. We are not responsible for requests that are not labeled or sent properly, or that do not have complete information. Please do not send us any sensitive personal information (e.g., social security number, passport number, national identification number) with your request.


7. Choices Under the California Consumer Privacy Act (CCPA)

This section provides further information about how we collect, use, and share personal information, describes specific rights that arise under the CCPA, and explains how to exercise these rights.

Selling Information. In the past 12 months, The Palms has sold or disclosed the following categories of personal information from California consumers: identifiers, online activity (i.e., how you use our site), financial information, and commercial information. The Palms has sold identifiers and information about how you use our site to our advertising partners, who use it to help us provide you with relevant advertising. We do not sell your information for any other purpose. We do not and will not knowingly sell personal information of minors who are younger than 16.

Requests. If you are a California resident, you can make the following requests:

  • Access Requests. You can request that we disclose certain information to you about our collection and use of your personal information in the past 12 months. Once we receive and verify your request, we will give you the following information:
    • The categories of personal information we collected about you.
    • The categories of sources of personal information we collected about you.
    • Our business or commercial purpose for collecting or selling that personal information.
    • The categories of third parties with whom we share that personal information.
    • The specific pieces of personal information we collected about you.

To make an access request, click here or call 1-800-550-0505.

  • Deletion Requests. You can request that we delete the personal information that we collected from you. Once we receive and verify your request, we will delete your personal information from our records. We are not required to delete information if we need to use it for the following:
    • Completing a transaction or contract with you.
    • Detecting security interests, protecting against malicious, deceptive, fraudulent, or illegal activity, or prosecuting people responsible for that activity.
    • Debugging our products to identify and repair errors to our Services.
    • Exercising, and allowing others to exercise, free speech, or other legal rights.
    • Internal uses that align with your expectations.
    • Complying with a legal requirement.
    • Other internal and lawful uses consistent with the reasons you provided the information.

To make a deletion request, click here or call 1-800-550-0505.

  • Sale Opt-Out Requests. You have the right to tell us not to sell your personal information. If you choose to opt out of sale, it means that going forward we will not share your information with advertising vendors who use it to help us provide you with relevant advertising, unless you later tell us to do so. For more information about this right, and to make a request, click here.

Making Requests. To make access or deletion requests, please click the links above, or call us at 1-800-550-0505. Before completing your request, we need to verify your identity. If you authorize someone else to make a request for you, we will need to verify that you have given them permission to make that request. We will send you a link to verify your email address.If the validation is not complete within 3 days, we will void your request and you will have to submit a new request.

Unless you make a request that is very difficult to respond to, we do not charge a fee to process your request. If your request requires a fee, we will tell you why, and give you an estimate of the cost.

We will not discriminate against you for exercising any of your California privacy rights.


8. How We Protect Your Information.

We use administrative, physical, and technological measures to protect your personal information’s confidentiality and security. Please be aware, however, that no set of security safeguards can prevent all instances of unauthorized access to or use of information.


9. Links to Other Sites

You may be able to access other sites from our Services. We recommend reading the privacy policies of these sites before using them. This Privacy Policy only applies to our Services.


10. Children's Privacy.

You must be at least 18 years old to use our Services. We do not knowingly collect, use, or disclose information from or about visitors under 13 years of age.


11. Privacy Policy Changes.

We recommend reviewing this Privacy Policy regularly to learn of updates to our privacy practices. We will try to notify you if we make any material changes to this Privacy Policy and, as necessary, obtain your consent to change how we use your information. Otherwise, you agree to any changes we make to this Privacy Policy by continuing to use the Services.

We may have other campaigns or promotions where other privacy practices or policies apply. We recommend reviewing these practices and policies before participating in these campaigns or promotions.


12. Transferring Data Abroad. If you visit the Services from a country other than the United States, you consent to us collecting, using, processing, storing, and transferring your personal information across international boundaries.


13. Governing Law

This Privacy Policy is subject to the laws of Florida.


14. Contacting The Palms

If you have questions about our Privacy Policy, please email us at privacy@thepalmshotel.com, or contact us at: 1-800-550-0505.