This Privacy Policy sets out how One Dalton LLC (“One Dalton”, “we”, “us” and “our”) collects, stores, processes, transfers, shares and uses personal information from visitors and users (“you”) to our website https://onedalton.com/, mobile sites, or applications (collectively, “Site”).

When completing the inquiry form on our website, you are providing us with information and indicating that you may have an interest in Four Seasons Private Residences One Dalton. We may contact you by the methods you provide, as well as subscribe you to our ongoing communications and event invitations. You may opt out of our emails and correspondence at any time.

Before accessing or using our Site, please ensure that you have read and understood how we collect, store, use and disclose your personal information as described in this Privacy Notice. By using the Site, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree to the terms, please do not access or use the Site.

Personal Information We Collect

The personal information we collect may include your name, email address, phone number and any other information you choose to provide to us.
Our Site is not directed to minors under the age of 16 and we do not knowingly collect or sell the personal information of minors. We do not knowingly collect any personal information, or knowingly track the use of our Site, from children. If we have actual knowledge that personal information about a child under 16 years old has been collected, then we will take appropriate steps to try and delete such personal information.

Use of Your Personal Information

We may use Personal Information for the following purposes:

To contact you: To contact you by email, telephone calls, or other equivalent forms of electronic communication.
To provide you with news or general information about goods, services, and events which we offer that are similar to those that you have already expressed interest in unless you have opted not to receive such information.
To manage your requests: To attend and manage your requests to us.

Retention of Your Personal Data

We will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Transfer of Your Personal Data

Your personal information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Processing of Personal Information and Cookies

When you visit our Site, you are given a “cookie”, and your computer is assigned an ID number. A cookie is a commonly used piece of software that tracks an individual user’s preferences and can enhance your visit to the site.
If permitted by your device settings, we and our third-party advertising partners may collect location data through GPS, Wi-Fi, or other methods to personalize and enhance your online experience and to improve the effectiveness of our website and communications. We collect analytics data or use third party analytics tools (elaborated on below) to help measure traffic and usage trends and to understand more about the demographics and behaviors of our users.
We, or our third-party partners, may use the data collected through cookies and similar technologies to provide custom, personalized content and information; identify and contact you across multiple devices; provide and monitor the effectiveness of our website and perform analytics; and otherwise, to plan for and enhance our online properties and services.
We may also use third party advertising companies to serve advertisements that may interest you when you access and use our website. To serve such advertisements, these companies place or recognize a unique cookie on your browser (including through use of pixel tags). Under no circumstances will we sell your information.

Third party analytics

We use Cookies and similar tracking technologies to track the activity on our Site. You can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if you do not accept Cookies, you may not be able to use some parts of our Site. Below is a summary of the third party analytics that we use:
- Google Analytics: Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
- Email Marketing: We may use your personal data to contact you with newsletters, updates, and event invitations sent via Mailchimp. Mailchimp is an email marketing sending service provided by The Rocket Science Group LLC. You may opt-out of receiving any, or all, of these communications from us by following the unsubscribe link.
- Remarketing: We may use remarketing services to advertise on third party websites to you after you visited our service. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our website.
- Google Ads (AdWords): AdWords remarketing service is provided by Google. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy

European Privacy Rights, Disclosures

This European Privacy Rights and Disclosure section addresses legal obligations and rights specified in the General Data Protection Regulation, or GDPR. These obligations and rights apply to individuals who are located in the European Economic Area.

We may process Personal Information under the following conditions:

Consent: You have given your consent for processing Personal Information for one or more specific purposes.
Performance of a contract: As necessary for the performance of an agreement with you and/or for any pre-contractual obligations.
Legal obligations: For compliance with a legal obligation.
Legitimate interests: Processing Personal Information is necessary for the purposes of the legitimate interests pursued by us.

Rights under the GDPR

You have the right under this Privacy Policy, and by law if you are within the EU, to:

Request access to Your Personal Information.
Request correction of the Personal Information that we hold about you.
Object to processing of your Personal Information.
Request erasure of your Personal Information.
Request the transfer of your Personal Information.
Withdraw your consent.

Exercising of Your GDPR Data Protection Rights

You may exercise your rights of access, rectification, cancellation and opposition by contacting us at the address in the contact section below. Please note that we may ask you to verify your identity before responding to such requests. You have the right to complain to a Data Protection Authority about our collection and use of your Personal Information. For more information, if you are in the European Economic Area (EEA), please contact your local data protection authority in the EEA.

International Data Transfers

When you are based in the European Union (the “EU”), Personal Information collected from you, including via the Site may be transferred to certain recipients located outside the EU, which do not provide a similar or adequate level of protection to that provided by countries in the EU. You hereby consent to the transfer of your Personal Information to recipients as described in this Privacy Policy which are located outside of the EU. You may withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

California Privacy Rights and Notice for California Residents.

In this section, we provide information for California residents, as required under California privacy laws, including the California Consumer Privacy Act (“CCPA”), which requires that we provide California residents certain specific information about how we handle their personal information, whether collected online or offline. This section does not address or apply to our handling of publicly available information made lawfully available by state or federal governments or other personal information that is subject to an exemption under the CCPA.

Categories of personal information that we collect. The table below sets out generally the categories of personal information (as defined by the CCPA) about California residents that we collect and disclose to others for a business purpose. We collect these categories of personal information from the sources described and for the purposes also detailed below.

Category	Examples	Collected
A. Identifiers.	A real name, alias, unique personal identifier, online identifier, Internet Protocol address, email address, account name.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, physical characteristics or description, address, telephone number, education, employment, employment history.	YES
C. Protected classification characteristics under California or federal law.	Age (40 years or older), national origin, citizenship, religion or creed, marital status, sex (including gender, gender identity, gender expression, sexual orientation.	NO
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	NO
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	NO
G. Geolocation data.	Physical location or movements.	NO
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information.	Current or past job history or performance evaluations.	NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO

Personal information does not include:

Publicly available information from government records.
De-identified or aggregated consumer information.
Information excluded from the CCPA’s scope, like:
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

Information from you that you actively provide: We collect this information from sources including from online forms, e-mail, and via telephone.
Information from you that you provide passively from your use of your sites and services: We collect this information from sources including from the Site, a web browser, or e-mail.
Third Parties (information we collect about you from third party sources): We collect this from sources including marketing partners, lead generators, and website and app vendors.

Use of Personal Information. We may use or disclose the personal information we collect for one or more of the following business purposes:

To fulfill or meet the services for which the information is provided.
To provide you with information, products or services that you request from us.
To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
To improve the Site and present its contents to you.
As described to you when collecting your personal information or as otherwise set forth in the CCPA.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information. We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Categories of Personal Information Sold. We do not, and will not, sell your personal information.

Rights of California residents. California law grants California residents certain rights and imposes restrictions on particular business practices as set forth below.

Do-Not-Sell: California residents have the right to opt-out of our sale of their personal information However, we do not sell your personal information.
Initial Notice: We are required to notify California residents, at or before the point of collection of their personal information, the categories of personal information collected and the purposes for which such information is used.
Request to Delete: California residents have the right to request deletion of their personal information that we have collected about them and to have such personal information deleted, except where an exemption applies. We will respond to verifiable requests received from California residents as required by law.
Request to Know: California residents have the right to request and, subject to certain exemptions, receive a copy of the specific pieces of personal information that we have collected about them in the prior 12 months and to have this delivered, free of charge, either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily useable format that allows the individual to transmit this information to another entity without hindrance. California residents also have the right to request that we provide them certain information about how we have handled their personal information in the prior 12 months, including:
- categories of personal information collected;

categories of sources of personal information;
business and/or commercial purposes for collecting and selling their personal information;
categories of third parties/with whom we have disclosed or shared their personal information;
categories of personal information that we have disclosed or shared with a third party for a business purpose;
categories of personal information collected;
categories of third parties to whom the residents’ personal information has been sold and the specific categories of personal information sold to each category of third party.

California residents may make a Request to Know up to twice every 12 months. We will respond to verifiable requests received from California residents as required by law.

Right to non-discrimination: The CCPA prohibits discrimination against California residents for exercising their rights under the CCPA. Discrimination may exist where a business denies or provides a different level or quality of goods or services, or charges (or suggests that it will charge) different prices, rates, or penalties on residents who exercise their CCPA rights, unless doing so is reasonably related to the value provided to the business by the residents’ data.
Financial incentives: A business may offer financial incentives for the collection, sale or deletion of California residents’ personal information, where the incentive is not unjust, unreasonable, coercive or usurious, and is made available in compliance with applicable transparency, informed consent, and opt-out requirements. California residents have the right to be notified of any financial incentives offers and their material terms, the right to opt-out of such incentives at any time, and may not be included in such incentives without their prior informed opt-in consent. We do not offer any such incentives at this time.

We will respond to verifiable requests received from California residents as required by law. For more information about our privacy practices, contact us as set forth in the “Contact Us” section below.

You may only make a verifiable consumer request to know information twice within a 12-month period. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Once we receive your verifiable consumer request, we will send you an acknowledgement letter within 10 days which will describe our verification process. We will respond to your request within 45 days, if we are able to verify your identity. Requests for deletion will require a separate confirmation that you want your information deleted.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Please note we are unable to disclose or provide you with your Social Security Number, Driver’s License Number, or other government issued identification number, financial account number, any health insurance or medical identification number, an account password, or security questions and answers.

“Do Not Track” Policy as Required by California Online Privacy Protection Act (CalOPPA)

We do not respond to Do Not Track signals. However, some third-party websites do keep track of Your browsing activities. If You are visiting such websites, ou can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable Do Not Track by visiting the preferences or settings page of Your web browser.

California Privacy Rights (California’s Shine the Light law)

Under California Civil Code Section 1798 (California’s Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties’ direct marketing purposes. If you are a California resident and you would like to request more information under the California Shine the Light law please contact us.

Changes to this Privacy Policy

We may update our Privacy Policy and we will notify you of any changes by posting the new Privacy Policy on this Site. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this Site.

Contact Us

If you have any questions about this Privacy Policy, please contact us at:

By email: info@onedalton.com

By phone: (617) 765-7855