Privacy Policy

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Table of Contents

<ul><li>Introduction & Scope</li><li>Information We Collect</li><li>How We Collect Information</li><li>How We Use Your Information</li><li>Cookies and Tracking Technologies</li><li>Third-Party Services & Social Media</li><li>Use of Images and Intellectual Property</li><li>Sharing & Disclosure of Information</li><li>Data Security & Retention</li><li>Your Rights and Choices</li><li>Policy Changes</li><li>Contact Information</li></ul>

Introduction & Scope

Legian Hotel Management (LHM) – including LHM’s corporate entity and its luxury Bali resorts (The Legian Seminyak and The Club by The Legian) as well as the main website (lhm-hotels.com) – is committed to protecting your privacy. This Privacy Policy explains how LHM and its affiliate properties collect, use, share, and safeguard personal information through our websites and during your interactions with our services. It covers all current and future LHM properties and platforms, and it is adopted in line with applicable laws (such as Indonesia’s Personal Data Protection Law and, where relevant, the GDPR). By using our website, making a reservation, or otherwise providing us with your information (for example through contact or subscription forms), you agree to this Policy and the use of cookies as described herein. LHM values your trust and treats your personal data with the utmost care. We maintain a data protection program that includes staff training, privacy impact assessments, and technical safeguards. All LHM employees and contractors with access to personal information are trained on privacy and security. We may provide links to our Cookie Policy or Terms of Use where noted; please review those documents for additional details.

Information We Collect

LHM collects various categories of information when you interact with us. This includes data you provide directly, as well as information gathered automatically or obtained from third parties. Key types of information include: <ul><li>Contact & Identification Data: Your name, email address, mailing address, phone number, date of birth or age and similar identifying information. (For example, a typical hotel form may ask for name, country of residence, and email to process a booking.)</li><li>Reservation & Stay Details: Information related to your booking or stay, such as reservation dates, room type, number of guests, special requests, travel itinerary, passport/visa or ID details, nationality, and any occasions or membership numbers (e.g. wedding anniversary, club membership) you provide.</li><li>Payment & Financial Data: Credit card and billing details used to guarantee or settle your reservation. All payment data is handled securely through PCI-compliant processes; LHM does not store full payment card numbers on our servers. We may retain transaction records (e.g. masked card numbers) to cover incidental charges or streamline future stays (as is standard practice).</li><li>Preferences & Interests: Any preferences you share with us, such as preferred room type, pillow and bed preferences, dietary restrictions, spa or dining interests, and feedback on past stays. We use this to personalize your experience (e.g. preparing your favorite pillow or catering to a food allergy).</li><li>Communications: Content of your communications with us, including emails, chats, reservation notes, feedback forms, and customer service calls. If you contact LHM by phone or live chat, those interactions may be recorded or logged (with notice) to improve service quality.</li><li>Site and Device Information: Data collected automatically when you visit our website or use our apps – for example, your IP address, browser or device type, operating system, language settings, referring URL (the site you came from), and pages viewed. This “usage data” helps us operate and optimize the site.</li><li>Cookies and Tracking Data: We use cookies and similar technologies (web beacons, local storage, pixels, etc.) to track site usage and preferences (see Cookies and Tracking below). These may collect or be associated with personal data if you are logged in or have otherwise provided information.</li></ul><ul><li>Images and Security Footage: LHM may collect images from security cameras (CCTV) in public areas of our hotels for safety and security. Photos or videos taken during events or by our staff (for marketing or documentary purposes) are used in accordance with this Policy. (All photographs on LHM’s own site are owned by LHM or its affiliates.)</li><li>Other Sources: We may obtain information from third parties, such as travel agents, booking partners, loyalty program networks, or publicly available databases. For example, we might receive your past reservation details from an affiliated travel site, or your social media profile information if you choose to log in via a social network. We may also use marketing data providers to enhance or confirm the information we have about you.</li></ul>In summary, the personal information we collect is typically what you provide to us directly (contact and reservation information), what we collect automatically (technical and usage data), and what is necessary to provide our services (payment, identity verification, etc.). This approach is consistent with industry practice.

How We Use Your Information

We use your information to operate our business and deliver the services you request, as well as for the following purposes (with your consent or as permitted by law):<ul><li>Provide and Personalize Services: We process your data to complete your bookings and fulfill your requests. This includes making and modifying reservations, processing payments, sending booking confirmations and pre-arrival emails, issuing electronic receipts, assigning room preferences, and providing customer service. For example, we may use your preference data (e.g. preferred room location or dietary restrictions) to improve your stay.</li><li>Improve Our Offerings: We analyze aggregated data to understand how guests use our websites, mobile apps, and on-site services. This analysis helps us improve our site design, troubleshoot technical issues, and develop new amenities or packages. For instance, we may analyze which web pages are most popular or track equipment usage in our wellness facilities. This enhances our service quality and efficiency.</li><li>Marketing and Promotional Communications: With your permission (and where required by law), we use your contact information to send you newsletters, promotional offers, special event invitations, or updates about our hotels and services. These communications may feature LHM properties (The Legian, The Club, etc.) or select partners. You always have the choice to opt in or out of marketing. Each marketing email or text will include clear unsubscribe instructions. (Even if you opt out of marketing, we will continue to send you transactional messages related to your bookings, such as confirmation emails or itinerary updates.)</li><li>Loyalty and Reward Programs: If you join any LHM loyalty or membership program, we will use your data to manage your account, track points or credits, and send you member-specific offers. This ensures we can provide all loyalty benefits and communicate program news.</li><li>Legal and Safety Purposes: We may use your information to fulfill legal obligations (such as tax or audit requirements), to resolve disputes, enforce our terms and policies, and to protect the safety of our guests and employees. This includes using surveillance footage for security purposes and sharing information with law enforcement if required by legal process.</li><li>Corporate Transactions: In the event of a merger, acquisition, bankruptcy, or sale of assets, your personal data may be transferred to the successor entity. Any such transfer will require the new entity to adhere to this Privacy Policy.</li><li>Other Purposes with Consent: We will also use your data for any other purpose for which you provided it (for example, a survey response), or as otherwise permitted by law.</li></ul>In essence, we use your personal information primarily to provide the services you request (hotel stay, reservation assistance, etc.) and to improve our offerings. We handle marketing carefully: only with your consent and always giving you an easy way to unsubscribe. Any use beyond what you expect will be clearly explained at the time we ask for your data.

Cookies and Tracking Technologies

LHM’s websites use cookies and similar tracking technologies to improve your browsing experience and to help us understand site usage. For example, we use:<ul><li>Essential Cookies: These are necessary for basic site functions like login, booking form processing, and security (preventing fraud). Without these, the site may not work properly.</li><li>Performance/Analytics Cookies: We partner with third-party analytics providers (e.g. Google Analytics, Inspectlet, Hotjar) to collect information about how visitors use our site (which pages they visit, how long they stay, etc.). This data is aggregated and used to make the site better.</li><li>Preference Cookies: These remember your language settings, currency choice, or other preferences to streamline future visits.</li><li>Marketing Cookies: We or our advertising partners may use cookies to display targeted ads or offers on other websites or social media platforms based on your browsing behavior. This is done with strict adherence to privacy laws (for example, EU users may need to opt in for this).</li></ul>When you first visit lhm-hotels.com, a cookie banner notifies you that “This site uses cookies… To find out more, read our Privacy and Cookie Policy”. You can choose to accept or customize your cookie settings. You may also disable or delete cookies through your browser, but please note that disabling some cookies may affect website functionality. For example, rejecting all cookies may require you to log in manually each visit and could break some interactive features. We do not respond to browser “Do Not Track” signals. However, you can limit targeted advertising by using opt‑out tools from self-regulatory programs (e.g. https://youradchoices.com) or by adjusting settings on your device.

Third-Party Services & Social Media

Our websites may include features and content provided by third parties. For instance:<ul><li>Social Media Links and Plugins: We may include links or embedded features for platforms like Facebook, Instagram, Twitter, YouTube, etc. Interacting with these features (e.g. clicking a “share” button) is done at your own discretion. Any information you share on social media is governed by that platform’s terms and privacy settings. LHM is not responsible for the privacy practices of social networks.</li><li>Payment Gateways: When you enter credit card details on our site to reserve a room, we use a secure third-party payment processor (e.g. a bank or payment platform). Your payment information is transmitted directly to them over an encrypted connection, and we do not store your full card data. Please review the payment provider’s privacy policy for more details on how they handle data.</li><li>Booking Engines and Hotel Platforms: If you use an external travel site or affiliate link to book LHM properties, those sites may have collected your information under their own policies before sending the reservation to us.</li><li>Content Delivery & Chat: We may use third-party services for interactive features (for example, video content may be hosted on Vimeo, or a chat widget may be powered by a bot). In those cases, some information (like your inputs in the chat or the fact that you accessed a video) may be shared with the service provider. Such providers handle data under their own policies, though we ensure they have contracts that require them to protect your data.</li><li>Advertising and Analytics: We may allow ad networks (e.g. Google Ads) and analytics vendors to place cookies or pixels on our site. These tools collect certain browser or device information (like IP address, pages viewed, or cookie IDs) to measure advertisement performance or user engagement. We only work with reputable vendors that follow applicable privacy regulations.</li></ul>Because third parties are independent, LHM’s Privacy Policy does not cover their practices. We encourage you to read the privacy policies of any linked sites or services you use. For example, if you follow our social media links or share content via a social platform, your data collection and usage on that platform are governed by that platform’s rules.

Use of Images and Intellectual Property

All visual content on LHM’s websites (photographs, graphics, logos) is the property of LHM or used with permission. These images are protected by copyright and may not be downloaded, reproduced, or used without our written consent. (As one third-party travel site notes, “All images are © The Legian Seminyak, Bali / LHM Hotels”.)With regard to personal images or video: by entering our hotels or participating in hotel-hosted events, you consent to potentially being photographed or filmed for security and promotional purposes. Any such media will be handled sensitively. For instance, CCTV footage is used strictly for safety and is not shared publicly. If we wish to feature guest likenesses in marketing materials, we will do so only with clear consent. If you supply us with any photographs or videos (e.g. by email or social media) for a contest or review, you grant LHM a license to use that content in our marketing channels. But remember that any content you post to public areas (like comments on our social pages) is also subject to that platform’s terms, not ours.

Sharing & Disclosure of Information

We do not sell your personal data. However, we may share your information in the following ways, strictly for legitimate business purposes and always under confidentiality:<ul><li>Internal Sharing: Authorized LHM employees and affiliated hotel staff (for example, front desk, reservations, or marketing teams) may access your data as needed to provide services. All LHM personnel are bound by confidentiality.</li><li>Group Companies and Owners: We may share relevant guest information with other LHM entities or with hotel owners in our group, strictly for purposes like managing your reservation, providing loyalty benefits, or sending you joint promotions. Any sharing within our family of hotels is done under strict controls and only as needed.</li><li>Service Providers: We engage trusted vendors to operate our business. These include reservation and booking platforms, payment processors, data storage providers, analytics firms, email and messaging services, and website hosts. For example, our hotel management system and booking engine will have access to the reservation and payment data in order to process your stay. Our vendors handle data only as instructed by LHM and under contractual obligations to protect it.</li><li>Marketing Partners: We may share limited data (such as email address or phone) with co-sponsors or promotional partners if you enter a joint contest or co-branded offer. For instance, if LHM teams up with a local spa or tour operator to offer a package, that partner may receive only the information needed to fulfill the package.</li><li>Advertising/Ad Tech Companies: We may work with advertising networks or social media advertisers to deliver targeted ads. In such cases, we may share hashed or anonymized data (like email addresses) under strict privacy rules. These companies are required to follow applicable laws and provide opt-out options for you.</li><li>Legal Authorities: We will disclose personal data if required by law (e.g. in response to a court order or subpoena), or if we believe in good faith that disclosure is necessary to comply with legal obligations, protect rights, or respond to fraud or security incidents.</li><li>Corporate Transactions: If LHM or a part of our business is sold, acquired, or undergoes restructuring, customer information may be transferred as part of that deal. We will require the new owners to honour this Privacy Policy.</li><li>With Your Consent: We will share personal data with any third party when you have given clear permission to do so (for example, we might share your contact details with a partner hotel chain if you request a room transfer).</li></ul>In all cases, the information we share is the minimum necessary for the purpose at hand. We hold our partners to high privacy standards. If you have concerns about a particular sharing scenario, please contact us (see below).

Data Security & Retention

LHM employs industry-standard technical and organizational measures to safeguard your data. This includes encrypting personal information during transmission (e.g. using SSL/TLS on our booking pages), storing data on secure servers with strong access controls, and regularly testing our systems against vulnerabilities. Payment card information is transmitted directly to a PCI DSS–certified processor; we never store the full card number on our systems. We also ensure that only authorized personnel have access to your data, and we require all staff to undergo privacy and security training as part of our data protection program. We retain your personal information only for as long as necessary to fulfill the purposes outlined in this Policy. For example, we may keep booking records for the duration of your stay and the few years following (to handle any follow-up service, billing or tax requirements). We retain marketing data only until you unsubscribe or withdraw consent. Starwood (a luxury hotel group) provides a useful guideline: “We retain your information for as long as needed... to comply with our legal obligations, resolve disputes, and enforce agreements”. Similarly, LHM will retain data in accordance with Indonesian law and any applicable international rules. When information is no longer needed, we will delete or anonymize it securely.

Your Rights and Choices

Depending on your jurisdiction, you may have certain rights regarding your personal data under laws like Indonesia’s PDPL, Europe’s GDPR, or California’s CCPA. These rights may include:<ul><li>Access: You can request a copy of the personal data we hold about you.</li><li>Correction: You can ask us to update or correct any inaccurate or incomplete information.</li><li>Deletion: You may request that we delete your personal data, subject to our legal obligations to retain certain records.</li><li>Portability: Where applicable, you can request that we transfer your data to another service provider in a usable format.</li><li>Restriction/Objection: You can request that we stop using your data for certain purposes (e.g. marketing).</li><li>Consent Withdrawal: If you have given consent for processing (such as subscribing to a newsletter), you can withdraw that consent at any time (e.g. by unsubscribing from emails).</li></ul>To exercise any of these rights, please contact our data protection officer or privacy team (see Contact Information). We will process your request in accordance with applicable law, typically within one month. In certain cases, we may need to verify your identity before responding. You also have the right to lodge a complaint with a supervisory authority if you believe your data is not handled properly. For example, a global hotel group notes that individuals can exercise rights by emailing their DPO (Data Protection Officer). LHM will ensure a similar mechanism – a dedicated email or form – is available for privacy inquiries.

Policy Changes

We may update this Privacy Policy from time to time (for example, if we introduce a new service, adopt a new technology, or in response to legal changes). If changes are significant, we will post a prominent notice on our website or send you an alert (for instance, via email if you are a subscriber). Otherwise, we will simply update the “Last Updated” date at the top of this policy. We encourage you to review our Privacy Policy periodically.

Contact Information

If you have any questions or concerns about this Privacy Policy or our data practices, please contact LHM’s privacy team:<ul><li>Email: info@lhm-hotels.com</li><li>Postal Address: Jalan Kayu Aya, Seminyak Beach, Bali 80361, Indonesia</li><li>Phone: +62 361 730622</li></ul>Our team will respond to privacy inquiries as soon as possible and in accordance with legal requirements. We also welcome feedback on ways to improve this Policy. By using LHM’s websites or services, you agree to the terms of this Privacy Policy. Thank you for trusting LHM with your personal information.

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