- What Personal Data Do We Process?
- How Do We Use the Personal Data We Collect?
- When Do We Share The Personal Information We Process?
- How Will We Protect Your Personal Data?
- How Long Will We Keep Your Personal Data?
- What Are Your Rights With Regard to Your Personal Data?
- What Are Your EU Rights With Regard To Your Personal Data ?
- What Are Cookies?
- What Types Of Cookies Do We Use?
- What Information Is Processed By Cookies?
- What Is Our Legal Basis For Processing Informaiton Collected By Cookies?
- What Other Information Should I Know?
- How Can You Contact Us?
Please review our Terms of Service which governs your use of the Services, whether online or in person, including when you:
- Interact with our properties, including our hotels, golf courses, clubs, spas, realty offices, brokerage, retail establishments and managed properties (“Properties”);
- Use of websites owned and controlled by Trump (“Sites”);
- Use of our mobile, web, tablet, desktop and other applications, including applications made available through Facebook, iOS and Android (the “Apps”); and,
- Use of any other content, applications, features, functionality, information and services offered by us, whether through our Apps, the Sites, at our properties or otherwise (collectively our “Services”).
Please note that when you visit a website operated by any of our third-party licensees, such as, developers or owners of Trump branded Properties, Trump does not control such websites and is, therefore, not responsible for those third parties’ privacy practices. This is true even though our branding may appear on those sites. Rather, you should look to those third parties’ privacy policies to know how they collect, store, use and share your information
2. What Personal Data Do We Process?
We process personal information or other information about you when you interact with any of our Properties, visit our Sites or otherwise use our Services. The information we may process depends upon your interaction with us. The types of personal data that we may process include the following:
- Reservations and Account Information: You may need to register for an account to access and use certain features, content or functions of the Services, for example, booking a hotel reservation, applying for membership at one our clubs, reserving a tee-time at a Trump course, making a restaurant reservation, purchasing products from the Trump Store or Trump Winery, signing up for loyalty programs or using any of our Apps. When you create an account, we will process personal data as necessary to offer and fulfill the Services you request. Depending on the Services you elect to use and only as necessary to provide such Services, we may ask you for your consent to process your name, date of birth, proof of identity (e.g., driver’s license number, security question), phone number, mailing address, email address, pet’s name, guests’ names, and login credentials (i.e., a unique user name and password or through your Facebook account). Also, when you book a reservation, we may ask for additional specific account information such as arrival and departure information, corporate account number, group or convention code, travel agent number or AAA number. If you limit our processing of this information that we obtained from you via consent, you may not be able to use all of the features of the Services.
- Additional Profile Information: We may also process descriptive information about our hotel guests, golf course members or players, customers (including prospective customers), residents and visitors so that we can best provide them with a personalized experience to fit their needs. Such information may include information or data relating to your room preferences, in-room dining preferences, Trump Attaché and other concierge services, preferred dining seating, equipment rental, leisure activities and interests, and other information as necessary to fulfill special requests made by you regarding your stay or services you request from us (e.g., health conditions that require special room accommodations or accessibility). We may also process other information associated with a guest’s stay, or a member’s, player’s, customer’s or other visitor’s use of the Services, such as the hotels where you have stayed, check-in/check-out dates, goods and services used, special requests made, observations about your service preferences (including room and vacation preferences, times of play, etc.), real estate preferences (e.g., attributes of properties you are interested in, desired neighborhoods or school districts), telephone numbers dialed and faxes, texts and telephone messages received
- Premises Security: We may also use closed circuit television and other security measures at our properties that may capture or record images of guests and visitors in public areas of our properties. We may also use closed-circuit television and other technologies that record sound or video for loss prevention and security purposes, and the protection of our guests and visitors to our properties where permitted by law.
- Payment Information and Purchase History: If you purchase products or offerings on or through our Services (e.g., Trump Store or Trump Winery) your payment information like your credit or debit card number, card type and expiration date and billing address . We may also use basic personal identifiers to fulfill your order and deliver the Services you requested, such as your name, date of birth and shipping address. Finally, we also process commercial information about your purchase and transaction history to improve your experience the details of any purchased services or products, including the date of purchase, rate or product purchase price, food/beverage purchase history, and any wording you may suggest for a gift card. This information may be processed by us and/or payment processors and service providers on our behalf.
- Additional Profile Information: We may also process information about our hotel guests, golf course members or players, customers (including prospective customers), residents and visitors so that we can best provide them with a personalized experience to fit their needs. Such information may include information or data relating to your room preferences, in-room dining preferences, Trump Attaché and other concierge services, preferred dining seating, equipment rental, leisure activities and interests, and other information as necessary to fulfill special requests made by you regarding your stay or services you request from us (e.g., health conditions that require special room accommodations or accessibility). We may also process other information associated with a guest’s stay, or a member’s, player’s, customer’s or other visitor’s use of the Services, such as the hotels where you have stayed, check-in/check-out dates, goods and services used, special requests made, observations about your service preferences (including room and vacation preferences, times of play, etc.), real estate preferences (e.g., attributes of properties you are interested in, desired neighborhoods or school districts), telephone numbers dialed and faxes, texts and telephone messages received.
- Images: We may also use closed circuit television and other security measures at our properties that may capture or record images of guests and visitors in public areas of our properties. We may also use closed-circuit television and other technologies that record sound or video for loss prevention and security purposes, and the protection of our guests and visitors to our properties where permitted by law.
- Payment Information and Purchase History: If you purchase products or services on or through our Services (e.g., Trump Store or Trump Winery) your payment information (e.g. credit or debit card number, card type and expiration date and address associated with such credit or debit card) and additional information to fulfill the services or deliver the products (e.g. name, date of birth and shipping address) may be processed by us and/or third party payment processors. We also process the details of any purchased services or products, including the date of purchase, rate or product purchase price, food/beverage purchase history, and any wording you may suggest for a gift card.
- Location Information: With your permission, we may process the specific geographic location of your Device (e.g. by accessing your Device’s GPS) via our Sites or Apps to provide you with directions to our properties or to determine your proximity to our properties or other specified location (for example, to determine yardage when playing a golf course). If no longer wish to have this location information processed, you can withdraw your consent at any time by disabling the location and/or Bluetooth features in the operating system of your Device and/or in the App. If you have any questions about disabling you location and/or Bluetooth features, you can contact us [email protected].
- Personal Data You Choose to Provide for Marketing or Additional Services: We may process personal data that you choose to provide to us when you elect to participate in optional Site-features or Services. For example, if you sign up to receive newsletters, marketing emails, promotions or other communications regarding the Services and/or promotions from our preferred third-party products or services or other Trump brands, participate in contests, surveys and other promotions related to the Services, we may process your name, email address, mailing address, gender, interests and phone number in order to provide the additional features or Services. We will make clear what information we may process as a result of your engagement with the optional Site-features or Services.
- Comments, Feedback, Customer Service and Other Inquires: You have the ability to use the Services to contact us with questions you may have, inquire about memberships, request to be contacted about properties available for sale or rent, provide us with comments and or feedback about the Services (e.g., completing a “Contact Us” form on our Sites or surveys relating to your hotel stay) or to communicate with other users of the Services and post comments to or otherwise interact with certain aspects of the Services that are available to the public and/or other users. We will process any information you submit, post or provide in the course of such activities to respond to your comments or feedback. In the event you contact one of our properties or customer call centers, we may process information related to conversations, including recording or monitoring customer service calls for quality assurance and training purposes, and to verify your identity.
- Application Information: When you apply for membership to any of our golf courses, clubs or loyalty programs, or submit an application(s) in connection with the rental or purchase of a property to our realty or brokerage service, we process information that you choose to provide to us through your application process, which may include your name, email address, mailing address, phone number, gender, date of birth, dependent information and references.
- Third Party Platform Information: If you access the Services by logging in using your account credentials from a third-party owned or operated platform/service (e.g., Apple (iTunes, etc.), Spotify, OpenTable, Facebook, Twitter, LinkedIn, etc.) (each, a “Third Party Platform”), post content from our Sites or Apps to a social network, or use various social media features (e.g., “Like” button), we may process certain information from the Third Party Platform, such as your username, “likes”, location, birthday, check-ins, comments and reviews, direct messages you may send to us, interests, photos, friends, status updates and other information you provided to the Third Party Platform in connection with your account. Depending on your account and privacy settings, we may also be able to see information that you post when using these Third Party Platforms whether or not you are using our Services. The information you post or provide to Third Party Platforms, as well as the controls surrounding these disclosures are governed by the respective policies of these third parties.
- Browsing Information, Logs, Usage Data and Other Device Information: When you visit our Sites and use our Apps, we may process information about your activities on our Sites and Apps through the use of technology such as cookies, web beacons and other tracking technologies, as further explained in Sections 13 – 17. Providing this information is not mandatory and cookies can be disabled by clicking here. However, please note that our Sites and Apps may not offer the same functionalities when certain cookies are disabled.
3. How Do We Use the Personal Data We Process?
To fulfill our contractual obligations under an existing agreement with you to provide you with products and services you requested, or in anticipation of entering into such an agreement with you, including, without limitation:
- To complete and fulfill your hotel reservation and stay, including, processing your payment, providing you with information relating your stay, sending you booking confirmations, cancellations, modifications or pre-arrival/post-arrival messages, and providing you with other information about the area and property in which you are going to stay;
- To communicate with you about your account, transactions, applications, the Sites and the Services;
- To respond to requests for information and services, including services from a third party (such as restaurants or transportation providers);
- To administer the Trump Card loyalty program, including sending you information about your account status and provide you with the benefits of the loyalty program;
- To manage, evaluate and administer applications you have submitted to us for membership and/or rental or purchase of real estate;
- To fulfill orders and provide you with products and services you have requested and/or paid for, including for our accounting, auditing or other internal functions, and to offer you an overview of your transactional history;
- To manage and administer your accounts, including sending you transaction-related emails for such things as account verification, purchase and billing confirmation, processing membership dues, and contacting references you provide;
- To enforce your legal rights under an agreement; and
- To provide you with an estimate for our products or services.
To pursue our legitimate business interests, including, without limitation:
- To provide you with a more personalized level of service, including information and services related to the products and services you purchase from us, available from a trusted third party (such as on-site restaurants and spas, local attractions and transportation options);
- To manage our business needs, such as monitoring, analyzing, modifying and improving our Services’, including the Sites’, functionality and performance, including changes/updates to features of the Sites/Apps, technical and security notices;
- For the security and safety of our guests, members and visitors, and for purposes of fraud prevention, including preventing fraud and abuse on and unauthorized access to the Services and Sites;
- To provide you with information about products and services you have purchased or indicated your interest in;
- To determine which features and functionality of the Services users like best to help us operate, enhance and improve the Services, including by asking you to participate in a survey relating your use of the Services;
- To respond to any customer service requests, such as resolving your problems or responding to your questions, managing any complaints or feedback you provide;
- For statistical analysis of aggregated data to help us segmenting our offering and develop our Services;
- To better understand the way in which our Sites and Apps are working and offer you a better Site and/or App user experience, to create statistics in relation to the use of our Sites, Apps and our Services generally;
- To help us diagnose technical issues and problems related to our Services;
- To grow our business, including our portfolio of Trump branded properties, products and services;
- To get to know our potential and existing guests, members, clients, consumers, and users; and
- To identify relevant content shared with potential and current users.
To comply with our regulatory and legal obligations or to enforce our legal rights, including, without limitation:
- To meet reporting requirements (e.g., filing tax forms);
- To retain documents and information related to a legal action;
- To enforce the Terms of Service; and
- To report data breaches or unauthorized access to the Services.
With your consent*, including, without limitation:
- To provide location-specific functionality, features, services or offers;
- To market to you by delivering marketing materials about our Trump brands, products and services, as well as the products and services of unaffiliated third party businesses;
- To display online advertising and marketing information based on your use of the Services and other websites services and platforms that you have visited;
- To provide you with tailored advertisements about our Trump portfolio of brands on third party websites, we may provide your personal information to Third Party Advertising Providers that combine such data with information collected by third-parties to send you advertisements on our Sites and third party websites, about our exclusive offers, brand news and events tailored to you and your interests;
- To provide personalized services offered by us on third-party websites and online services;
- To enable you to connect with others who use our Services; and
- For other purposes for which you may grant consent.
4. When Do We Share The Personal Information We Process?
In connection with our global operations, we may share information we collect from you or about you with some of our affiliates, licensees and third party service providers as necessary to assist us in providing the Services to you, as set forth in more detail below:
Our Group Entities: We may disclose your personal data to our group entities that are affiliates and/or subsidiaries or parents of Trump to provide you with tailored products, services and communications.
Service Providers: We may partner with other companies to help us operate certain aspects of our businesses, including the hosting of our Sites and Apps, operation of our technology infrastructure, processing of payments and reservations, and fulfillment certain of the services or products you request from us. We carefully select such third party operators, merchants, website hosts, service providers and participants to your transactions, including our on-property service providers, such as our spa operators, restaurants, valets and concierge services, for the purpose of (1) assisting with facilitating transactions on or through the Services, (2) providing information technology and customer service assistance, and (3) providing, offering, supporting, administering, maintaining and enabling the Services (including providing a full range of content, activities, services, features and functions offered on or in connection with the Services).
Advertising Providers: In order to provide you with marketing and exclusive offers, including emails and advertisements tailored to you and your interests on and off the Services, we may provide your information to Third Party Advertising Providers.
Co-Sponsors of Promotions: From time to time, we may co-sponsor promotions, sweepstakes, prize draws, competitions or contests with other companies. If you enter one of these sweepstakes or contests, we may share your information with the co-sponsor or third-party sponsor.
Credit Authorization: When you submit an application for the purchase or rental of real estate, or membership at one our golf courses or clubs, your personal information will be used and disclosed to appropriate third parties in accordance with applicable laws for the purpose of determining your credit worthiness and whether to approve your application.
Corporate Transactions or Events: We may disclose your personal data in connection with a merger, sale of substantially all of our assets or stock, joint venture, transfer, corporate reorganization or other disposition of our business.
To Fulfill Your Requests: If you elect to use certain authentication or sharing features available on the Sites or via the Services, we may use your personal data to fulfill your request to share content with or provide access to such third parties (e.g., Facebook, LinkedIn, or Twitter).
Can Children Use Our Sites and Apps?
Our Sites and our Apps are not directed to children under the age of majority. We do not knowingly collect information via our Sites and Apps from children or other individuals who are not legally able to use our Sites and/or our Apps. If we obtain actual knowledge that we have collected personal data from someone under the age of majority, we will promptly delete it unless we are legally obligated to retain such data. If you believe that we have mistakenly or unintentionally collected information from someone under the age of majority, please contact us at [email protected]. For users in the United States, please also visit ftc.gov for information from the Federal Trade Commission about protecting children’s privacy online.
5. How Will We Protect Your Personal Data?
While no data transmission over the internet or wireless networks is 100% secure from intrusion, we maintain and have implemented reasonable physical, electronic, technical and procedural security policies and measures to protect the personal data that we process, which are consistent with applicable privacy and security laws. These policies and measures are designed to prevent against loss, misuse, unauthorized access, modification and disclosure and unlawful destruction of your personal data. The security measures can change and be modified over time, but generally include, but are not limited to, firewalls, data encryption, physical access controls to our data centers, servers and hardware and information access authorization controls, regular testing and updating of the systems and training programs.
6. How Long Do We Keep Your Personal Data?
7. What Are Your Rights With Regard To Your Personal Data?
How to Unsubscribe from Trump Hotels’ Marketing: If you want to unsubscribe from receiving tailored advertisements on third party sites (as described in “Advertising Data” in Section 2) and/or marketing emails sent by or on behalf of Trump Hotels, you can do so by visiting our email subscription center or by following the instructions in any such marketing email you receive from us.
How to Unsubscribe from Other Trump Brands’ Marketing: If you want to unsubscribe from receiving tailored advertisements on third party sites (as described in “Advertising Data” in Section 2) and/or marketing emails sent by or on behalf of all other Trump brands, you may unsubscribe by emailing [email protected] (by clicking [email protected], an auto-filled email will be generated and you must hit “send” to submit your unsubscribe request) or by following the instructions in any such marketing email you receive from us.
How to Cancel Your Loyalty Membership: To end your Trump Card membership, please email [email protected]
Modifying Privacy Settings: You also may be able to adjust certain privacy, permission and user account settings under the Trump Hotels emails subscription center, by responding to request alerts or notifications on your Device or by navigating to the settings, account or privacy section (as the case may be) of your Device or the applicable Third Party Platform and limiting certain Service functionality (e.g., location services, etc.). Please be aware that if you limit the collection of certain information, you may not be able to use all of the features and functionality of the Services.
8. What Are Your EU Rights With Regard To Your Personal Data?
If you are in the EU, you may have certain additional rights with respect to the personal data you provided to us. To the extent permitted by applicable data protection laws, under EU laws you may have:
The Right to Access: You have the right to request copies of your personal data. We may charge you a small fee for this service.
The Right to Rectification: You have the right to request that we correct any information you believe is inaccurate. You also have the right to request we complete information you believe is incomplete.
The Right to Erasure: Under certain conditions, you have the right to request that your personal data be erased, under certain conditions.
The Right to Restrict Processing: Under certain conditions, you have the right to restrict the processing of your personal data.
The Right to Object to Processing: Under certain conditions, you have the right to object to the processing of your personal data.
The Right to Data Portability: Under certain conditions, you have the right to request we transfer the Personal Information that we have collected to another organization, or directly to you.
How to Exercise these Rights: If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at:
The Trump Organization, c/o Privacy Administrator
Attn: EU Privacy Rights Request
725 Fifth Avenue
New York, New York 10022
Although we urge you to contact us to find a solution for every concern you may have, you always have the right to lodge a complaint with your competent data protection authority. Please note that some requests may require you to verify your identity.
Will Personal Data be Transferred Outside of the European Economic Area (EEA)?.
Our operations are supported by a network of computers, cloud-based servers, and other infrastructure and information technology, including, but not limited to, third-party service providers. We and some of our subsidiaries and affiliates, servers, vendors and service providers may not be located in your jurisdiction and may also be located outside of the European Economic Area and Switzerland. If you are an EU citizen or resident in the EU, we will transfer your personal data to the United States in accordance with EU data protection law requirements by using model contractual clauses that have been approved by the European Commission or other appropriate means.
Please note that such transfers may also be necessary in order to perform our obligations under a contract with you, to fulfill a request made by you, to meet a legal or regulatory obligation and/or through obtaining you express consent. If you make transactions with parties outside the EEA or Switzerland or connect our Service with platforms, such as Facebook, outside the EEA or Switzerland, we are required to transfer your Personal Data with those parties in order to provide the requested Service to you. If you wish to gain more information about such transfers, please contact us at [email protected].
WHAT ARE YOUR CALIFORNIA RIGHTS WITH REGARDS TO YOUR PERSONAL DATA?
If you are a California Resident, you may have specific rights over your personal information including:
The Right to Know: You have the right to request information about:
- The categories of personal information we collected about you;
- The categories of sources from which we collected that information;
- Our business or commercial purpose for collecting that information;
- The categories of third parties with whom we shared that information; and
- The specific pieces of personal information we collected about you in the past 12 months.
You also have the right to request a copy of your personal information.
The Right to Deletion: Under certain conditions, you have the right to request that we delete your personal information. Please note that simply uninstalling the App or Services does not delete your account or the personal information we may have collected.
Selling Your Personal Information: Trump does not intend to sell your personal information to third parties without providing you notice and an opportunity to opt out.
How to Exercise these Rights: To submit a request to exercise these rights you may contact us at:
The Trump Organization, c/o Privacy Administrator
Attn: CA Privacy Rights Request
725 Fifth Avenue
New York, New York 10022
All requests must be labeled “Your California Privacy Rights” on the email subject line or envelope or post card. For all requests, please clearly state that the request is related to “Your California Privacy Rights”, include your name, street address, city, state, zip code and e-mail address (your street address is optional if you wish to receive a response to your request via email) and indicate your preference on how our response to your request should be sent (email or postal mail). We will not accept requests via fax. We are not responsible for notices that are not labeled or sent properly, or that do not have complete information. You can always opt-out or unsubscribe by emailing [email protected].
Before we can provide you with information, however, we will need to verify your identity using the personal information you recently provided to us. If we are not able to verify your request we will contact you for more information, or we may deny the request and we will explain the basis for the denial. Please note the procedures are intended to protect individuals’ privacy.
Designating an Authorized Agent: You may designate someone to submit requests and act on your behalf (an “Authorized Agent”). To do so, you must provide us with written permission to allow your Authorized Agent to act on your behalf.
No Discrimination: We will not unlawfully discriminate against you for exercising any of these rights.
Do Not Track: We may collect information about your internet activity to help us provide you with relevant advertisements, incentives or offers. Some web browsers or smartphones have the ability set “Do Not Track” requests to block user activity from being tracked across web pages or devices. The Apps and Sites do not recognize “Do Not Track” signals.
Unsubscribing from Direct Marketing: You may exercise your choice to know what third parties we may have shared your personal information with for their direct marketing purposes. You also have the right to opt out of such information sharing by exercising the unsubscribe options listed above in Section 7.
9. What Are Cookies?
10. What Types Of Cookies Do We Use?
We do not place cookies until you elect to continue using our Site after our cookie banner displays.
Our cookie management tool uses Cookiepedia to, with no input from us, automatically categorize cookies that we deploy on our Sites. We use the following types of cookies:
Strictly Necessary Cookies: These cookies are necessary for the Sites to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the Site(s) may not work if you choose to do so.
Performance Cookies: These cookies allow us to count visits and traffic sources, so we can measure and improve the performance of our Sites. They help us know which pages are the most and least popular and see how visitors move around the Sites. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies, we will not know when you have visited our Site(s).
Functional Cookies: These cookies allow the provision of enhanced functionality and personalization, such as videos and live chats. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies, then some or all of these functionalities may not function properly.
Targeting Cookies: These cookies are set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant ads on other sites. They work by uniquely identifying your browser and Device. If you do not allow these cookies, you will not experience our targeted advertising across different websites.
11. What Information Is Processed By Cookies?
12. What Is Our Legal Basis For Processing Information Collected By Cookies?
By continuing to browse on our Site(s) you consent to us deploying cookies as described in this policy. If you do not wish to accept cookies from our Site(s), or would like to stop cookies being stored on your Device in the future, you can change your settings in our
Cookie Settings here.
13. What Other Information Should I Know?
14. How Can You Contact Us?
The Trump Organization
Attn: Privacy Matters
725 Fifth Avenue
New York, New York 10022