Effective date: 12.24.2019
The Los Angeles Athletic Club (“LAAC,” “us”, “we”, or “our”) operates the http://www.laac.com, www.laachotel.com, www.mylaac.com, mercuryathletica.com, woodenaward.com, and affiliated websites (“Websites”), and provides various services to our community members, including our state-of-the-art athletic and spa facilities, award-winning restaurants, bars, luxury meeting, conference, and hotel rooms, and an array of social, business, athletic events, and other hospitality services (hereinafter collectively referred to as the “Services”).
- Personal Information (also known as “Personal Data”): Personal Information means data about a particular individual or household that identifies, relates to, describes, could be reasonably linked with, or could be used to identify that person or household (or from those and other information either in our possession or likely to come into our possession). It also includes other information that may be associated with your Personal Information, such as your Usage Data (defined below), location, preferences or interests, if that information can be used to identify you or your household.
- Services: As noted above, our Services include the http://www.laac.com website operated by the Los Angeles Athletic Club, our state-of-the-art athletic and spa facilities, award-winning restaurants, bars, luxury meeting, conference, and hotel rooms, and an array of social, business, athletic events, and other hospitality services.
- Usage Data: Usage Data is data collected automatically either generated by the use of the Website or from the Website infrastructure itself (for example, your IP address or the duration of a page visit).
- Cookies: Cookies are small files stored on your device (computer or mobile device).
- Data Processors: Any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various partners in order to process your data more effectively.
- User (or “Data Subject”): Any individual who uses our Services and is the subject of Personal Information collected and/or processed.
Information Collection and Use
a. Types of Data Collected
We collect several different types of information for various purposes to provide and improve our Service to you.
- Personal Information. While using our Services, we may ask you to provide us with or otherwise obtain certain personally identifiable information that can be used to contact or identify you (“Personal Information,” as defined above). Such Personal Information may include, but is not limited to your name, address, email address, driver’s license information, username, payment card information, Social Security number, credit report, marital status, bank account and/or direct billing information, credit report, and any other information that may identify you.
- Usage Data. We may also collect information on how you access and use our Services (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Services that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
- Generic Information. Generic information is information that does not directly reveal the identity of a LAAC member, customer, or visitor to the Website. This information may include Usage Data and other aggregate usage metricssuch as total number of Website visitors, pages viewed, and usage patterns within the Website, etc. This may also include information about your device. We may automatically gather some Generic Information from our members, customers, and Website visitors. At times, the combination of various types of data, including Generic information and Usage Data, may enable you to be identified, and may therefore qualify as Personal Information.
Some of the cookies we use are “strictly necessary” for the functionality of our Websites. Others improve the functionality of our Websites but are not strictly necessary. Some cookies help improve the performance of our Websites (such as by gathering analytic data), while others help provide targeted services to you (like ads that you may be interested in).
Examples of Cookies and other technologies we may use include:
- Session Cookies. We use Session cookies to operate our Website.Session cookies are temporary, and are automatically deleted once you close your Internet browser.
- Preference Cookies. We use Preference cookies to remember your preferences and various settings. Preference cookies are first party that cookies remain on your computer hard drive until you delete them or until they are otherwise removed upon expiration
- Pixel tags. Pixel tags and web beacons are tiny graphic images placed on website pages or in our emails that allow us to determine whether you have performed a specific action. When you access these pages or open or click an email, the pixel tags and web beacons generate a notice of that action. These tools allow us to measure response to our communications and improve our web pages.
- Other Technologies. We collect many different types of information from other technologies to improve the quality of our Website and the services we provide. For example, we may collect Usage Data and other information about the device you use to access our Website, your operating system and/or mobile device type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. We may record the IP address of the device you use to connect to the Internet.
Your Cookie Choices
How We Collect Your Information
LAAC collects and obtains your information in a few ways: there is information that you choose to give to us, information we obtain through your use of our Services – including our Website – and information we obtain from third parties.
a. Information You Give Us
We collect information that you decide to share with us. At times, we may require you to provide certain information – including Personal Information – in order to use certain parts of our Website, fulfill your requests with us, or provide you with certain Services. For instance, we may require you to provide your name, email address or other contact information when you contact us with a question or comment. If you establish a membership account with us, we may require you to create a username and password to access our Member Login portal at www.mylaac.com. Additionally, we may need you to provide certain Personal Information to book a room with our hotel, sign up for a membership, or to use other portions of our Services.
b. Information We Obtain When You Use Our Services
As noted above, we collect certain information from you through your use of our Services, such as Usage Data. For instance, in using our Website, we may collect information about the device you use to log into, access, and use the Website. We may collect other Generic Information in relation to how you use our Website or other Services (for example, aggregate metrics on how often certain pages on our Website are accessed and viewed).
We also may collect information through the use of cookie, pixel tags, or other technologies, as described above.
c. Information We Obtain from Third Parties
We may also obtain limited information about you from our third party business facilitation partners who help us provide our Services to you. For example, if you visit the on-site LA Barbershop, we may obtain your information from the LA Barbershop if you charge any services or goods directly to your room or membership account.
We may also receive information about your credit history from third party credit bureaus. This information is used to determine how much credit to extend as part of your membership (for instance, if you wanted to charge drinks at our bar against your membership account).
We also receive information from certain business facilitation partners that help facilitate your reservation with the LAAC Hotel. This information can include your name, address, phone number, email, other contact information, and/or your method of payment.
Purposes for Collecting, Processing, and Using Your Information
a. Business and Commercial Purposes for Collection
LAAC collects, processes (or asks our business facilitation partners to process on our behalf), and uses your information to provide the Services we make available to you. We therefore will collect and use your information for a variety of reasons, including:
- To perform a contract with you, or provide those Services you have requested of LAAC (for instance, we need to collect and process your information when you become a member of LAAC, stay at our hotel, enjoy our restaurants and bars, etc., in order to provide those services to you).
- You have otherwise given us your consent and permission to do so (for example, you have consented to receive our newsletter and provided your email address for that purpose).
- To facilitate providing our Websites and other Services that we offer to you. These operational purposes may include but are not limited to:
- Operating, maintaining and improving of our Services, including the Websites;
- Detecting security incidents;
- Detect, prevent, and address technical issues; and
- Protecting against and helping law enforcement to prosecute individuals responsible for malicious, deceptive, fraudulent, or illegal activity.
- The collection and processing is related to another LAAC business or commercial purpose. For instance, we may use you information to assist with fraud prevention, improve the security of our networks, assist with enhancing the physical security of our guests, customers and members, and reporting suspected criminal activity to law enforcement. We may also use your information in relation to certain marketing events and promotions we think may be of interest to you.
- To comply with applicable laws, in response to a lawful and enforceable request by a law enforcement, judicial, or other public authority, or in connection with an applicable legal obligation.b. Legal Bases for Processing and Using Your Information (EU data subjects)
Similar to the purposes for collecting your information, LAAC processes the information of EU Data Subjects for the following reasons:
- Fulfilling a Contractual Obligation: the processing is necessary to perform a contract with you.
- Consent: you have otherwise given us your consent and permission to do so – for instance, if you provide us your email address to our newsletter, or willingly provided your information to us to provide feedback on or ask us questions about our Services.
- Legal Obligation: To comply with applicable laws, in response to a lawful and enforceable request by a law enforcement, judicial, or other public authority, or in connection with an applicable legal obligation.
- Legitimate Interest: The collection is in our legitimate interests or the legitimate interests of a third party, and is not outweighed by any applicable rights you may have. For instance, we may use you information to:
- Assist with fraud prevention.
- Improve the security of our networks.
- Operate, maintain and improve our Services, including the Websites.
- Prevent, detect, and address technical and security incidents.
- Report suspected criminal activity to law enforcement.
- To provide customer support to you and our other members, customers, and visitors.
How We Use Your Information
Such other general uses include:
- To provide and maintain our Services.
- To notify you about changes to our Services.
- To allow you to participate in interactive features of our Services when you choose to do so.
- To allow you to charge meals, drinks, services, and other amenities directly to your room or membership account.
- To pay your membership fees and other charges directly from your financial account.
- To assess your membership credit amount and limits.
- To provide customer support to you and our other members, customers, and visitors.
- To gather analysis or valuable information so that we can improve our Services.
- To monitor the usage of our Services.
- To detect, prevent and address technical issues.
- To provide you with news via our newsletter, special offers, marketing or promotional materials, and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired, or which we believe may be of interest to you, unless you have opted not to receive such information. You may opt out of receiving any, or all, of these communications from us by contacting us at the contact information listed below.
- Various aspects of the Website, such as content on the Website, and email messages we send you in connection with your use of the Website may include advertisements that may be selected for you based on your demographic information, interests, preferences, and usage patterns within the Website.
How We Disclose or Share Your Information
LAAC does not sell your information to any third party. However, LAAC may disclose your information in a number of ways in order to provide our Services to you. For instance, we may share your information with our third party business facilitation partners that facilitate the functions of our Website, such as our web hosting and cloud storage providers. We may also share or disclose your information to those third party business facilitation partners that facilitate our membership, hotel, and restaurant services, and other amenities available to you, such as providing your credit card number to a third party payment processor when you make a reservation with us.
Wemay also provide your Personal Information to business facilitation partners or contractors to perform functions on our behalf including companies or individuals hired to publish and operate the Website, communicate news, deliver our promotional materials via e-mail and direct mail, promote our social media presence and activities, develop, enhance, market, or provide any of our products, and assist us with sending communications and performing other marketing and support functions.
We may also disclose or share your information for the following purposes:
- To comply with a legal obligation.
- To protect and defend LAAC’s rights or property.
- To prevent or investigate possible wrongdoing in connection with the Services.
- To protect the personal safety of users of the Services or the public.
- To protect against legal liability.
- When there is a good faith belief that such action is necessary to investigate or protect against harmful activities to our guests, visitors, associates, or property (including the Website), or to others (including LAAC itself). This may include disclosures to law enforcement to investigate potential criminal activity or other civil violations.
a. Categories of Third Parties that Receive Personal Information from LAAC
We share or otherwise disclose individuals’ personal information to the following categories of third parties:
- Business Facilitation Partners: We employ third party business facilitation partners, companies, individuals, and agents to facilitate and help us provide our Services to you. Such partners perform tasks or functions on our behalf, provide Services-related services, or assist us in analyzing how our Services are used or delivered. These third parties are granted access to your information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. For more information on the analytic partners we use to better understand how you and other visitors use our site, please go to the “Analytics” section below.
- LAAC Affiliated Vendors: Some of the amenities that we offer to you at LAAC are actually fulfilled or provided by LAAC affiliated vendors, such as the LA Barbershop. LAAC may share your information with these vendors in order to provide the Services you requested or otherwise enhance your experience at LAAC. For instance we may need to provide your membership or room information to the LA Barbershop if you bill the LA Barbershop’s services directly to your LAAC account.
- Other LAAC Entities: We may share or disclose your information to other LAAC entities.
Collection Agencies: Sometimes we may need to share individuals’ information with collection agencies to help bring past-due accounts up-to-date.
b. Categories of Personal Information Disclosed
LAAC has disclosed the following categories of Personal Information in the last 12 months for a business or commercial purpose:
- Member names;
- Membership information;
- Payment card or other billing information;
- Hotel reservation information (including payment information);
- Social Security numbers (solely to facilitate bringing past-due accounts up-to-date).c. Categories of Personal Information Sold
LAAC does not sell individuals’ information without their permission. LAAC has not sold Personal Information to third parties in the past 12 months.
Please note that a “sale” of Personal Information does not include those instances when such information is part of a merger, acquisition, or other transaction involving all or part of our business. If we sell all or part of our business or make a sale or transfer of assets or are otherwise involved in a merger or other business transaction, we may transfer your Personal Information to a third party as part of that transaction. If such transaction materially affects the manner in which your Personal Information is processed, we will notify you of such change prior to its implementation.
Retention of Data
We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Services, or we are legally obligated to retain this data for longer periods.
Transfer of Data
LAAC’s Services – including the Los Angeles Athletic Club, our hotel and event space, spa, restaurants, and other amenities – are offered and available to individuals in the State of California.
Your information, including 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 from those of your jurisdiction.
Security of Data
The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information from loss, misuse, and unauthorized access, alteration, disclosure, and destruction, we cannot guarantee its absolute security. By using or Website and Services, you acknowledge that there are data security and privacy limitations inherent to the use of the Internet, and that the security, integrity, and privacy of any and all information exchanged between you and LAAC, or between you and other related entities, cannot be guaranteed. We cannot ensure or warrant the security of any information you transmit to us or that we store, and you do so at your own risk.
Our Policy on “Do Not Track” Signals under the California Online Protection Act (CalOPPA)
We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set 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. We do not track consumers’ online activities over time and across third-party Web sites or online services.
Third parties may collect data that relates to you. We cannot control third parties’ responses to do-not-track signals or other such mechanisms. Third parties’ use of data relating to you and responsiveness to do-not-track signals is governed by their respective privacy policies.
Your Data Protection & Privacy Rights
California residents and data subjects in the EU / European Economic Area (“EEA”): LAAC aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Information, and exercise other rights available under applicable law. LAAC therefore informs you that, where applicable under relevant law, you are entitled to the following:
- Right to Access / Disclosure: to have access to your Personal Information upon simple request – that is, you may receive a copy of such data upon receipt of a verifiable request, along with other information related to the processing.
- Disclosure of Direct Marketers: California residents have the right to have access upon simple request, and free of charge, the categories and names of addresses of third parties that have received Personal Information for direct marketing purposes. Please see the “Your California Privacy Rights” section below for more information.
Right to Information About Selling, Sharing, or Disclosing Personal Information: upon receipt of a verifiable request, California residents may obtain a list of:
- The categories of Personal Information collected about you, sold to third parties, or disclosed to third parties for business purposes;
- The categories of Personal Information sold within the last 12 months;
- The categories of sources from which Personal Information is collected;
- The business or commercial purpose for collecting or selling Personal Information; and
- The categories of third parties with whom Personal Information is shared, sold, or disclosed for a business purpose.
- Right to Opt-Out of the Sale of Personal Information:California residents have the right to opt-out of the sale of their Personal Information under certain circumstances. As noted elsewhere,however, LAAC does not sell individuals’ Personal Information.
- Right to Correction: to correct your Personal Information if you find it is inaccurate, incomplete or obsolete.
- Right to Deletion / “Right to be Forgotten”: to obtain the deletion of your Personal Information in the situations set forth by applicable data protection law.
- Withdraw of Consent to Processing: for EU data subjects, you may withdraw your consent to the data processing without affecting the lawfulness of processing, where your Personal Information has been collected and processed based on your consent and not any other basis.
- Right to Object: for EU data subjects, you may object to the processing of your Personal Information under certain circumstances, in which case we may ask you to justify your request by explaining to us your particular situation.
- Right to Restrict Processing: for EU data subjects, you may request limits to the processing of your data, when allowed by and in circumstances set forth under applicable law.
- Right to Data Portability: to have your Personal Information directly transferred by us to a third-party processor of your choice (where technically feasible; may be limited to situations when processing is based on your consent).
- Right to Non-Discrimination. As defined under relevant law, California residents have a right to non-discrimination in the Services or quality of Services you receive from us for exercising your rights.
Please contact us at the information in “Contact Us” Section below in relation to exercising these rights. Note that we may ask you to verify your identity before responding to such requests.
Additional Rights for EU Data Subjects
EU data subjects also have the right to complain to a Data Protection Authority (“DPA”) about our collection and use of your Personal Information. For more information, please contact your DPA. EU data subjects also have the right to object to automated decision-making that produces a legal effect on the data subject.
Your California Privacy Rights
If you are a California resident, you have the right to request information from us regarding the manner in which we share certain categories of personal information with third parties for their direct marketing purposes, in addition to the rights set forth above.
Under California law, you have the right to send us a request at the designated address listed below to receive the following information:
- the categories of information we disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year;
- the names and addresses of the third parties that received the information; and
- if the nature of the third party’s business cannot be determined from their name, examples of the products or services marketed.
To make such a request, please provide sufficient information for us to determine if this applies to you, and attest to the fact that you are a California resident. Please also provide a current California address for our response. You may make this request in writing to us at the below postal address. Any such request must include “California Privacy Rights Request” in the first line of the description, and include your name, street address, city, state and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through the address provided for this purpose below.
Note that responsive information may be provided in a standardized format that is not specific to you.
We may use third-party Business facilitation partners to monitor and analyze the use of our Website.
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 Website. This data is shared with other Google services. Google Analytics may collect your IP address information as part of its services, which may qualify as Personal Information under certain circumstances.
For more information on Google’s privacy practices, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en.
Links to Other Sites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Our Website is intended for adult audiences, and is not meant to address anyone under the age of 18 (“Children”). As such, children under 18 may not use our Website. If you are under 18, do not attempt to register for or use our Website and do not provide us any Personal Information about yourself.
Submitting a Verifiable Request to LAAC
As mentioned above, California residents and European data subjects have certain rights to access, correct, delete, or otherwise control the use, collection, and/or disclosure of their information. LAAC will respond to an individual’s “verifiable request” to exercise his or her rights under such laws – that is, where LAAC has received a request claiming to be from a particular person, and LAAC has been able to verify that person is who they say they are. The need to verify a person’s identity is critical to protecting your information, and ensuring that your information is not shared with anyone pretending to be you or someone who is not authorized to act on your behalf.
You may submit a verifiable request via our email address, mailing address, or toll-free number, listed in the “Contact Us” section below, or as otherwise provided on our Website. LAAC will ask you to provide information about yourself so that we can verify your identity as part of this process. This information may include your name, your address, information related to your membership or account, and any other information deemed necessary by LAAC to reasonably verify your identity, to ensure that your information is not shared with anyone impersonating you.
We may ask for additional information if we have difficulty confirming your identity. We will not share your information or honor other requests in those situations in which we are unable to confirm a request for your information is a “verifiable request.”
Please note under California law that a consumer can appoint an “authorized agent” to make certain verifiable requests upon their behalf, such as the right to know what information we collect about the consumer or to request deletion of the consumer’s information. Because the security, integrity, and privacy of your information is paramount, we will ask that you identify and provide permission in writingfor such persons to act as your authorized agent and to exercise your applicable rights under California law in such situations. This may require us to contact you directly and alert you that an individual has claimed to be your agent and is attempting to access or delete your information. We will also independently verify your identity to ensure that an unauthorized person is not attempting to impersonate you and exercise your rights without authorization. We will not share your information or honor any other requests in those situations where you cannot or do not grant permission in writing for an identified authorized agent to act on your behalf, or where we cannot independently verify your identity.
431 West 7th street
Los Angeles, CA 90014
By email: LAAC.PrivacyPolicy@laac.net
By phone: 213.630.5200
By webform: please click here to submit your request.
To Complete a Rights Request (California Residents & EU Data Subjects)
As noted above, California residents and EU data subjects have certain rights in relation to their personal information. Such individuals can exercise their rights to their Personal Information by contacting us using the methods detailed above. Please note that we will only process valid rights requests as they apply to California residents and EU data subjects.
As part of your rights request, you will need to identify which rights request you wish to make:
- Disclose the categories of personal information about me that LAAC has collected.
- Disclose the specific personal information about me that LAAC has collected.
- Disclose the categories of personal information about me that LAAC has shared with third parties; or
- Delete my personal information.
Additionally, you will need to provide the following information so that we can validate your identity:
- Your First, Middle and Last Name (include your name at the time of membership, reservation and stay with the LA Athletic Club, or other contact with us as well if different from current);
- Your full Date of Birth
- Last four digits of your Social Security number
- Your phone number.
- Your full home address and ZIP code.
- Your LA Athletic Club membership number
- For reciprocal club members, your club name and membership information
- Your Email Address (include your Email Address at the time of membership, reservation and stay with the LA Athletic Club, or other contact with us as well if different from current email address)
The information we gather from your submission will only be used for validation purposes and will be deleted after your identity is verified. If we are unable to verify your identity, we will be unable to honor your requests.
Additionally, if you made a request for the specific pieces of information collected about you, or if you made a request to delete your information, we will need you to also separately provide a written declaration signed under penalty of perjury (such as a notarized declaration) that you are the person to whom the request relates. Please provide your written declaration to us at the postal address above.