OUR COMMITMENT TO PRIVACY

Orton and its affiliates (“Orton”) are committed to your privacy. We want you to be familiar with how we collect, use and disclose information. This Privacy Policy describes our practices in connection with information that we collect online and offline:

WHAT INFORMATION WE COLLECT

“Personal Information” is information that identifies you as a natural person or relates to an identifiable natural person. We may collect and process the following Personal Information:

  • Personal contact information such as name, address, telephone number and email address;
  • Business contact information such as business address, telephone number and email address;
  • Information necessary to provide services or products to you;
  • Comments and opinions you provide when you contact us directly by email, telephone or mail;
  • Payment and transaction information for billing purposes.

HOW WE COLLECT PERSONAL AND OTHER INFORMATION

We and our service providers may collect Personal Information online in a variety of ways in connection with our services or products, including:

  • Through our websites (“Websites”);
  • Through the software applications made available by us for use on or through computers and mobile devices (“Apps”);
  • Through social media properties (“Our Social Media”);
  • Through HTML-formatted email messages that we send to you that link to this Privacy Policy (“Emails”);
  • Through extranet sites made available to our clients and third parties (“Extranet Sites”);
  • Through services we provide to our corporate and institutional clients (“services”); and
  • Through our registration process for newsletters, seminars, webinars and events.

We also may collect Personal Information offline in a variety of ways in connection with our, including

  • When you participate in a contractual arrangement for services or products;
  • When you provide information in conjunction with our services or products; or
  • When you interact with us at an event.

We also may collect Personal Information from other sources, including:

  • Publicly available databases;
  • Joint marketing partners and event sponsors, when they share the information with us;
  • Other entities or franchisees to which we provide products and services;
  • Referral sources; and
  • Social media platforms.

We need to collect Personal Information in order to provide our products and services to you. If you do not provide the information requested, we may not be able to provide our products or services. If you disclose any Personal Information relating to other people to us or to our service providers in connection with our products and services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

We and our service providers may collect Other Information in a variety of ways, including:

  • Through your browser or device:
    • Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the services (such as the App) you are using. We use this information to ensure that the services function properly.
  • Through your use of an App
    • When you download and use an App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.
  • Using cookies
  • Using pixel tags and other similar technologies
    • Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the services and response rates.
  • Analytics
  • IP Address
    • Your IP address is automatically assigned to your computer by your Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses our systems, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other systems. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the systems. We may also derive your approximate location from your IP address.

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.

HOW WE USE PERSONAL INFORMATION

We and our service providers use Personal Information for legitimate business purposes, including:

  • Providing Products and Services.
    • To contact individuals (including employees of institutional clients) in connection with providing products and services.
    • To respond to inquiries and fulfill requests from our clients and others, administer their file(s), provide products and services and manage our relationships.

We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.

  • Providing you with our marketing materials and facilitating social sharing
    • To send you our offers, newsletters, publications, updates, and mailings related to our products or services that we think may be of interest to you.
    • To fulfill your event or accommodation registration requests and provide goods and services and resort services.
    • To send you information about our products and services and other news about products or services which we have reason to believe will be of interest to you.

We will engage in this activity with your consent or where we have a legitimate interest.

  • Providing the functionality of our Products and Services and fulfilling your requests
    • To provide our products and services functionality to you, such as arranging access to your registered account, and providing you with related goods and services.
    • To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise (e.g., when you send us questions, suggestions, compliments or complaints, or when you request other information about our products or services).
    • To send administrative information to you, such as information regarding our products and services, guarantees and warranties and changes to our terms, conditions and policies.

We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.

  • Accomplishing our business purposes
    • For data analysis, for example, to improve the efficiency of our goods and services and quality of our products.
    • For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements.
    • For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft.
    • To meet our legal and regulatory obligations.
    • For enhancing, improving, or modifying our current products and services.
    • For identifying usage trends, for example, understanding which parts of our products and services are of most interest to customers.
    • For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our customers.
    • For operating and expanding our business activities, for example, understanding which parts of our services or products are of most interest to our customers so we can focus our energies on meeting our customers’ interests.

We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.

HOW LONG WE RETAIN PERSONAL INFORMATION

We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include:

  • The length of time we have an ongoing relationship with you and provide our products and services to you (for example, for as long as you have an account with us or keep using our products and services);
  • The length of time we have an ongoing relationship with you as our client and provide you with products and services;
  • Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions or communications for a certain period of time before we can delete them); or
  • Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

WHAT SECURITY MEASURES WE USE

We have implemented internal policies and technical measures to protect Personal Information from loss, accidental destruction, misuse or disclosure. Such internal policies and technical measures include:

  • The use of pseudonymization and encryption of personal data where appropriate;
  • Procedures and controls to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
  • Procedures and controls to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident;
  • Procedures for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing; and
  • Procedures to ensure that data is not accessed, except by individuals in the proper performance of their duties.

UPDATES TO THIS PRIVACY POLICY

The “LAST UPDATED” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy. Your use of our online services following these changes means that you accept the revised Privacy Policy.

HOW TO CONTACT US

Orton is the company responsible for collection, use and disclosure of your Personal Information under this Privacy Policy.

If you have any questions about this Privacy Policy, please contact us info@ortonbaths.com