Last Updated: February 17, 2023
Four Seasons Hotels and Resorts (“Four Seasons”, “we”, “us” or “our”) takes the issue of safeguarding your privacy seriously. Our Privacy Notice describes what personal information we collect from or receive about you and the ways in which Four Seasons uses that information.
Four Seasons collects and handles the personal information of the following categories of individuals:
- Hotel and resort guests and patrons, Residence Club and Private Residence owners and prospective owners, renters and guests, Private Jet Experience travelers as well as participants in other Four Seasons journeys and experiences (collectively referred to as “Guests and Owners”);
- Travel agents and preferred partners; and
- Visitors to Four Seasons websites (including the Four Seasons Online Shop (shop.FourSeasons.com) that post, refer or are otherwise subject to this Privacy Notice, and mobile App users. Such websites and our mobile App are collectively referred to as our “Sites”.
This Privacy Notice has been adopted by all of the distinct legal entities that manage and operate Four Seasons branded hotels, resorts, Residence Club and Private Residence properties around the world (each a “Property”, and collectively referred to as “Properties”). A complete list of such entities, and additional information relevant to Four Seasons’ processing of personal information, is available here. Those entities include Four Seasons Hotels Limited and its direct and indirect subsidiaries and affiliates, and all of the separate and distinct legal entities that manage Four Seasons Properties. References to “we”, “us”, “our” or “Four Seasons” throughout this Privacy Notice refer collectively to those separate and distinct legal entities, or to individual entities, depending on the context.
What personal information do we collect?
Personal information is any information that may identify or relate to you as an identifiable individual. The personal information that we collect or receive about you could include the following categories of information:
- Identity information – such as name, age, gender, passport information or data from other government-issued identity cards or from your accounts created on our Sites;
- Contact information – such as your home address, zip/postal code, email address and phone number;
- Images – such as CCTV images, publicly available photographs and images captured at events or during your stay;
- Financial and payment information – such as your credit card details, itemized spending, billing address, and transaction history;
- Reservation information – such as the type and location of the rooms you reserve, restaurant and spa treatment reservations, experiences you book, other guests associated with your reservations, and the dates of your reservations;
- Health information – where provided to us and relevant to the provision of services;
- Preference information – including but not limited to preferred pillow type and mattress firmness, special requests, interests, and data related to past service issues;
- Purchase history – details of your purchases at our Properties and on our Sites, including on the Four Seasons Online Shop, and delivery address;
- Public information – such as when we review public platforms to understand more about you, or what you are saying about us or the hospitality industry;
- Technical information – such as information about the device you use to interact with us (including the hardware model, IP address, geolocation data, operating system and version, and, in the case of your use of our mobile App, mobile network information and unique device identifiers); and
- Correspondence information – when you contact us, such as to send an inquiry or make a request, any correspondence or application may be kept, and information derived from such correspondence may be added to your personal information.
How do we use your personal information?
For each of the categories of personal information described above, we use your personal information for the following purposes:
- if you create an account on a Site, or become a Guest and/or Owner and we create an internal profile about you, to remember your information and preferences to personalize your experience and provide customer service;
- to help us recognize or identify you and any online accounts or internal profiles related to you, for instance as a visitor to our Sites, or as a Guest and/or Owner;
- to allow you to log-in to your account online or through our mobile App by sending a one-time passcode to your phone (via SMS) or email address depending on how you elect to receive such a passcode;
- to enable you to use our Sites;
- to assist us in making reservations for you and providing the services you request at any of our Properties;
- to process transactions through our Sites (including taking payment for purchases you may make) and to assist in any inquiries about your transaction;
- for billing purposes in relation to your stays with us;
- to confirm prior transactions and reconcile statements or invoices;
- to consolidate your accounts on our Sites;
- to contact you in relation to matters regarding your stays with us or purchases from the Four Seasons Online Shop;
- to send you newsletters or marketing communications regarding our Properties or products and to advise you of promotions or to inform you of offers or other information that may be of interest to you (if, where required by law, you separately provide your consent for us to do so);
- to personalize and enhance your online, Guest and/or Owner experience;
- to conduct surveys or focus groups to obtain your views regarding our Properties and service delivery (if, where required by law, you separately provide your consent for us to do so);
- to respond to specific requests for information from you about one or more of our Properties and handle any other inquiries, correspondence, concerns or complaints you have raised;
- for marketing, advertising and promotional purposes, such as through one of our online promotions or on third party social networks, consistent with your preferences and applicable law;
- to analyze customer trends and insights;
- to operate our business, including for internal purposes such as auditing, data analysis, statistical and research purposes, and troubleshooting to help us improve our services;
- for other purposes disclosed at the time you provide your personal information or as otherwise set forth in this Privacy Notice; and
- for the establishment, exercise, or defence of legal claims or proceedings.
We will combine information from a number of our Guests and/or Owners as well as visitors to our Sites to better understand trends and your expectations. When this occurs, all identifiers are removed and the aggregated information cannot be linked to any specific individual or household and is therefore no longer personal information.
On what bases do we use your personal information?
We use your personal information on the following bases:
- to enter into agreements with you – we use your personal information to perform our agreement to provide services to you when you stay or otherwise engage with us, or to take steps at your request prior to entering into such an agreement;
- for legitimate business purposes – using your personal information helps us to operate and improve our business and minimize any disruption to the services that we may offer to you. We may also use your personal information to make our communications with you more relevant and personalized, and to make your experience of our services more efficient and effective;
- because you have given your consent – at times we may ask for your consent to allow us to use your personal information for one or more purposes, such as to send you marketing communications. See the “What rights do you have regarding your personal information?” section for more information about the rights that you have if we process your information on the basis of your consent; and
- to comply with legal and regulatory obligations – such uses of your personal information may include financial reporting requirements imposed by government regulators or our auditors.
How and from what sources do we collect personal information?
For each of the categories of personal information and purposes described above, we gather information when you provide it to us directly, or otherwise interact with us, for example:
- when you create an account or sign in to access an existing account on our Sites;
- when you comment on or interact with our digital posts or ads on social media platforms or other partnering websites such as Google or LinkedIn;
- when you make a purchase through our Sites;
- when you make a reservation online, by calling one of our Worldwide Reservation Offices or by contacting a particular hotel or resort directly; and
- during your experience as a Guest or Owner, including information provided during check-in and through the mobile App during a stay.
We also collect your personal information while monitoring our technology tools and services, including email communications sent to and from Four Seasons and the use of the chat functionality on our Sites.
We may also receive information about you from other sources. These include our business partners and trusted third party service providers. For example, we receive information about you when you use the Four Seasons Online Shop (shop.fourseasons.com), which is operated on our behalf by a trusted third party provider. The sources also include other members of your traveling party or other individuals (for instance, an authorized travel agent or personal assistant), as well as information that is made publicly available on the internet such as your picture, which we may use for recognition purposes to provide customer service when you visit our Properties. We may also combine information that we have about you from various sources, including the information that you have provided to us.
We, or our third party partners, may use the data collected through cookies and similar technologies to remember information about you for the following purposes: so that you will not have to re-enter it on our Sites; to provide custom, personalized content and information; to identify and contact you across multiple devices; to provide and monitor the effectiveness of our Sites; generate analytics; to diagnose or fix technology problems; to detect or prevent fraud or other harmful activities; to personalize and enhance your experience and to improve the effectiveness of our Sites, offers, advertising, communications and customer service, and otherwise to plan for, optimize and enhance our online services.
How do we protect personal information?
We use a variety of physical, technical and organizational security measures and technologies to help preserve the integrity and security of your personal information, consistent with applicable data protection and privacy laws. Such measures include, but are not limited to, adopting monitoring and governance policies and processes, technical and physical access controls, use of encryption technologies, employee training, and the regular audit and maintenance of our systems.
We endeavor to protect the privacy of your online account and internal profile as well as other personal information that we hold in our records, but unfortunately, we cannot guarantee complete security. Unauthorized access or use, hardware or software failure, and other factors may compromise the security of user information. Also, while we endeavor to put adequate contractual protections in place, we cannot guarantee the security of any personal information in databases hosted by third parties.
It is important to note that any email communication is not secure. This is a risk inherent in the use of email. Please be aware of this when requesting information or sending forms to us by email (for example, from the “Contact Us” section of fourseasons.com). We recommend that you do not include any confidential information (such as credit card information) when using email. For your protection, our email responses to you will not include any sensitive personal information.
Finally, to be prudent, please be sure to always close your browsers when you are done using a form or making an online reservation. Although the session will terminate after a short period of inactivity, it is best to close your browsers immediately upon completion, especially when using a public computer or a private computer in a public setting.
Will personal information be provided to third parties?
For each of the categories of personal information described above, we may share certain of your personal information with:
- other Four Seasons Properties;
- Four Seasons Residence Club Property sales specialists;
- agents, contractors or third party service providers of Four Seasons who provide services to Four Seasons or on our behalf, including as needed to better serve your needs as a Guest or Owner, or visitor to our Sites;
- escrow agents, third party lenders and loan-servicing agents;
- a prospective buyer, investor or other third party in the event that we are involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of any business or assets or similar business transaction;
- our professional advisors and auditors;
- local or foreign regulators, governments, courts, health and safety authorities, law enforcement and relevant security authorities; and
- others with your consent or at your direction.
Where a third party engaged by Four Seasons processes personal information on our behalf, Four Seasons takes steps to contractually require those parties to protect your personal information in a manner consistent with the principles articulated in this Privacy Notice.
In the case of third party residential property developers, please visit the particular developer’s privacy notice to learn more about the personal information practices of the third party developer.
If you have chosen to join a subscription list, please note that such lists are only used for internal purposes and we do not sell or rent our subscription lists to third parties for their direct marketing purposes.
If Four Seasons suspects any unlawful activity is taking place, it may investigate and/or report its findings or suspicions to the police or other relevant law enforcement agency.
We may also disclose information as may be required by law or legal process, or if we reasonably believe such disclosure is necessary to comply with legal process or the reasonable requests of law enforcement or to exercise or protect the rights, property or personal safety of Four Seasons, our Guests or Owners, or others.
Will your personal information be transferred outside your home country?
Your personal information may be processed by Four Seasons and its third party service providers anywhere in the world, including in countries where data privacy laws may not be equivalent to, or as protective as, the laws in your home country.
In particular, your personal information will be stored in your guest profile in our central reservation system located in Canada, and is available to all Four Seasons Properties.
We will implement appropriate measures to ensure that your personal information remains protected and secure when it is transferred outside of your home country. These measures include data transfer agreements implementing standard data protection clauses and transmitting data in accordance with applicable legal requirements. To request additional information regarding these data transfer agreements, please contact our Chief Privacy Officer (see the “Contact us” section below).
What rights do you have regarding your personal information?
Depending on the applicable law, which may be determined by your country, region or state of residency, you may be able to exercise one or more of the following rights relating to our processing of your personal information. You may also have other rights under the laws of your jurisdiction of residence.
To protect your privacy, we may require that you prove your identity to us at the time your request is made. This may involve providing us with information which we hold on file about you (for example, a home or business address), or information regarding your past stays at Four Seasons Properties.
Accessing, correcting or deleting your personal information
We understand that you may wish to know what personal information we hold about you, or request that we correct or delete certain information. We are happy to assist you with such requests.
Four Seasons reserves the right to decline a request to access, correct or delete your personal information under certain circumstances as permitted by applicable law. In particular, there may be a variety of legitimate business reasons or legal obligations that allow or require us to retain your personal information.
Right to decline marketing communications
If you do not wish to receive marketing communications from Four Seasons you can send such a request via email to: email@example.com, or, at Properties where consent is collected on registration cards, you may indicate your wishes on your registration card. You will always have the ability to accept or decline any form of marketing communication from Four Seasons. You may unsubscribe from electronic marketing communications at any time by selecting the “unsubscribe” link included in such communications. Please note that you may not be able to opt-out of service-related communications (such as account verification emails, transactional communications, and technical and security notices).
You may also be entitled to:
- object to the processing of your personal information;
- request the restriction of the processing of your personal information;
- opt-out from the processing or disclosure of your personal information for direct marketing purposes;
- withdraw your consent to the processing of your personal information (where Four Seasons is processing your personal information based on your consent); and
- request the receipt (or transmission to another organization) of the personal information Four Seasons holds about you in a machine-readable form.
Where you are given the option to share personal information with Four Seasons, you can always choose not to do so.
If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw that consent, we will respect that choice in accordance with our legal obligations.
This could mean that we are unable to perform the actions necessary to achieve the purposes of processing described above (see “How do we use your personal information?”) or that you are unable to make use of the services we offer.
After you have chosen to withdraw your consent, Four Seasons may continue to process your personal information to the extent required or otherwise permitted by law.
If at any time you wish to exercise any of these rights, you can do so by:
For hotel and resort Guests, contacting our Corporate Guest Historian:
- via email at firstname.lastname@example.org
- via fax at 1 (416) 441-4676
- if you live in California, toll-free at: 1 (855) 538-9044
- via letter at -
Attention: Corporate Guest Historian
Four Seasons Hotels and Resorts
1165 Leslie Street
Toronto, Ontario M3C 2K8
For Residence Club and Private Residence Owners, by contacting the Director of Residences at your home Property, or by using any of the methods described immediately above.
Alternatively, you can contact our Chief Privacy Officer via the details in the “Contact us” section.
You may make a request through an authorized agent (such as a lawyer). We may request evidence of their authority to act on your behalf.
For how long is my personal information retained?
Your personal information will be stored for the period of time required or permitted by law in the country in which it is stored, including the jurisdiction of any Property holding the information. This may involve retaining information following your stay. We will delete your personal information once it is no longer reasonably necessary for any of the purposes described in this Privacy Notice.
We will also keep your personal information where we need to do so in connection with a legal action or an investigation involving Four Seasons.
Any financial information Four Seasons retains will be protected under the terms of this Privacy Notice and, where financing is arranged in the United States, under the Financial Services Modernization Act.
How is personal information affected by business transactions and/or transfers?
Four Seasons manages Properties on behalf of third party property owners. Four Seasons may disclose to such a property owner certain Guest or Owner information as needed to implement business transactions between the Property and a particular Guest or Owner. All other personal information is considered to be proprietary to Four Seasons and is not shared with property owners. If we cease to manage a particular Property, guest information required to process pending reservations and information that was historically shared with the property owner will be retained by the property owner. All other personal information remains with Four Seasons.
What laws apply to this notice?
Four Seasons Hotels Limited does business worldwide as Four Seasons Hotels and Resorts and is a Canadian corporation incorporated under the laws of the Province of Ontario, Canada. As such, Canada's Personal Information Protection and Electronic Documents Act applies to our company. We apply the requirements of this law (and any other applicable laws such as the European Union’s General Data Protection Regulation) to how we handle personal information. Each Property managed by Four Seasons also complies with the local privacy laws of the jurisdiction where it is located. All transfers of personal information between countries will be subject to the terms of this Privacy Notice and completed in compliance with applicable laws.
If you have additional questions regarding the law or if you feel we have not treated your personal information appropriately, you may contact The Privacy Commissioner of Canada (https://www.priv.gc.ca/en/) as follows:
- via toll-free number at 1 (800) 282-1376
- via phone at 1 (819) 994-5444
- via email at email@example.com
- via online form, which is available here
- via letter at –
The Office of the Privacy Commissioner of Canada
30 Victoria Street
You may also have the right to file a complaint with the local data protection supervisory authority in your home country.
How will third party websites use your personal information?
Our Sites may include links to third party websites, plug-ins and applications. We are not responsible for, and this Privacy Notice does not apply to, any personal information practices of third party websites and online services or the practices of other third parties (except where we expressly adopt, incorporate, apply or refer to this Privacy Notice). To learn about the personal information practices of third parties, please visit their respective privacy notices.
Updates to this Privacy Notice
We will update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the “Last Updated” date at the beginning of this Privacy Notice and will provide any other form of notice as may be required by law. All changes shall be effective from the date of publication unless otherwise stated.
If you have any questions or concerns regarding this Privacy Notice or our handling of your personal information, please contact our Chief Privacy Officer as follows:
- via email at firstname.lastname@example.org
- via letter at –
Chief Privacy Officer
Four Seasons Hotels and Resorts
1165 Leslie Street
Toronto, Ontario M3C 2K8
Additional Notice under Japan’s Act on the Protection of Personal Information (“APPI”): Four Seasons Hotels Limited and the separate and distinct legal entities that manage Four Seasons Properties in Japan (as identified here) carry out a joint use of personal information as stipulated under Japan’s APPI. In particular, the data categories that are subject to such a joint use are described in the section called “What personal information do we collect?”. Additionally, the purpose of utilization of such personal information can be found in the sections of this Privacy Notice called “How do we use your personal information?” and “On what bases do we use your personal information?”. With respect to the jointly used personal information, Four Seasons Hotels Limited and the Four Seasons Properties in Japan work together to respond to requests from individuals related to their rights under the APPI. Contact information for Four Seasons Hotels Limited, and information on exercising rights under the APPI, can be found in the “What rights do you have regarding your personal information?” section.
Four Seasons Hotels Limited’s Legal Representative for the purposes of this disclosure is Four Seasons’ Chief Privacy Officer ( email@example.com ).
Additional Notice under the South Africa Protection of Personal Information Act (“POPIA”): The definition of personal information referred to in this Privacy Notice is expanded to also cover an identifiable, existing juristic person, where it is applicable. Details on requests for information as contemplated under Section 51(1)(e) of the Promotion of Access to Information Act (“PAIA”) can be found in a Manual maintained by Four Seasons Hotel, The Westcliff, Johannesburg, which is available at www.fourseasons.com/johannesburg.